The respondent father moved to change child support orders from 2007, seeking recalculation and retroactive reduction based on changed circumstances and alleged double-dipping by FRO.
The applicant mother opposed the motion.
The court dismissed the father's motion, finding he failed to provide admissible evidence of a material change in circumstances or new evidence, and that his claims of physical limitations and misrepresentation of income were unsubstantiated and not properly before the court.
The court emphasized the payor's burden to prove a material change and the inadmissibility of unsworn evidence.