McCormick v. McCormick

“When a party seeks to modify the child support provision of a prior order or judgment, including an order or judgment incorporating without merging an agreement or stipulation of the parties, he or she must demonstrate a substantial change in circumstances” (Matter of Malbin v Martz, 88 AD3d 715, 716 *683[2011]; see Domestic Relations Law § 236 [B] [9] [b] [2] [i]; Matter of Brescia v Fitts, 56 NY2d 132, 140-141 [1982]). Contrary to the Family Court’s determination, here, the mother established that an increase in the father’s child support obligation was warranted by a change in circumstances…