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IN RE ZIKMANIS

No. 2009-275.

993 A.2d 249 (2010)

In the Matter of Audrey ZIKMANIS and Mark Peabody.

Supreme Court of New Hampshire.

Opinion Issued: April 8, 2010.

Attorney(s) appearing for the Case

McLane, Graf, Raulerson & Middleton, P.A., of Manchester (Jennifer L. Parent and Jeanine M. Kilgallen, on the brief), for the petitioner.

Mark Peabody, pro se, filed no brief.

DUGGAN, J.

The petitioner, Audrey Zikmanis (wife), appeals a recommendation of the Master (Green, M.) approved by the Superior Court (Abramson, J.) modifying the parties' child support obligation. She argues that the trial court erred in: (1) modifying a valid support order as a sanction for her conduct; and (2) modifying the support obligation retroactively and prospectively when no request for modification was pending, and without obtaining current...

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