In Jutchenko v. Jutchenko, 283 N.J. Super. 17, 660 A.2d 1267 (App.Div.1995), the Appellate Division held that the Act did not apply to allegations of domestic violence between brothers who had not resided in the same household for 20 years "at least in the absence of any showing that the alleged perpetrator's past domestic relationship with the alleged victim provides a special opportunity for 'abusive and controlling behavior.'" Id. at 20, 660 A.2d 1267.