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In the February 12, 2019 unpublished case of Agarwal v. Agarwal Docket # 340133, the Michigan Court of Appeals affirmed the trial court’s decision to prohibit the distribution of Education Saving Accounts to either party, indicating that Michigan divorces statutes do not permit the courts to order conveyance of property or interest in property to third parties. Citing the published case of Gates v. Gates 256 Mich App 420 (2003) as their rational.