The parties disputed a claimed retroactive downward variation of child support, the structure of resumed parenting time with the younger child, and whether the mother required the father's travel consent for international vacations.
Applying the retroactive support framework, the court held the payor failed to prove a real, significant, and continuous material decrease in income, finding the medical evidence insufficient and the non-employment effectively a matter of choice.
On parenting, the court found a material change arising from the lack of consistent visits and ordered a gradual transition of day visits before restoring alternate weekend parenting time with the younger child only.
On travel, the court held the father's refusal to consent to a one-week vacation was unreasonable and varied the prior order to permit international vacation travel of up to two weeks outside school time without his authorization, subject to itinerary disclosure and make-up parenting time.
