Ludlow v. Ludlow

—Order, Supreme Court, New York County (David Saxe, J.), entered January 26, 1994, which, inter alia, held in abeyance defendant’s motion to vacate a judgment of divorce and a prior order directing a downward modification of plaintiff’s support obligation, both of which were granted upon defendant’s default, pending receipt of a report from the Special Referee to hear and report with recommendations on the issues of personal jurisdiction in the divorce action, proper notice of the hearing in the downward modification application, and prejudice to defendant, if any, resulting from plaintiff’s…