Under the parties' 1996 separation agreement incorporated but not merged into their 1996 judgment of divorce, petitioner was awarded custody of both the parties' son and daughter. For reasons not presently in issue, respondent was given temporary custody of the son in 1999. Respondent continued to pay the child support directed in the judgment until March 2004, when, three months after having been awarded permanent custody of the son, he sought a downward modification based...
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