A downward modification of alimony was properly denied for failure to make the showing required of plaintiff in the parties' 1978 separation agreement, incorporated but not merged into their 1978 divorce judgment, namely, "a substantial downward change in his financial circumstances." Indeed, plaintiff's income now is more than twice what it was in 1978. Plaintiff argues that his current income is derived from assets rather than earnings, but, under the circumstances, including...
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