MATTER OF LEVINE-SEIDMAN v. SEIDMAN

2011-02119.

88 A.D.3d 883 (2011)

931 N.Y.S.2d 125

2011 NY Slip Op 7428

In the Matter of DEBBIE LEVINE-SEIDMAN, Respondent, v. KURT SEIDMAN, Appellant.

Appellate Division of the Supreme Court of New York, Second Department.

Decided October 18, 2011.


Ordered that the order is affirmed, with costs.

Although the Family Court found that the father failed to show an "unanticipated" and "unforeseen" change in circumstances warranting a downward modification of his child support obligation, because the father's obligation was not contained in a stipulation of settlement that had been incorporated but not merged into a judgment of divorce, the standard that should have been applied is "a substantial change in circumstances...

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