In a Decision – Abate v. Abate (an "Unreported Decision") >> the Court Held:
The Appellate Division determined that the Father had not established the bases for the reduction in support.
he court affirmed holding plaintiff-father’s unemployment may only be temporary and noted he was still receiving severance pay. As such, the family court properly found plaintiff-father “failed to demonstrate that his alleged change in circumstances was anything but temporary.” Further, denial was warranted as plaintiff-father failed to meet the requirements of Rule 5:5-4(a) which required a movant to submit both a current and a prior CIS. Because plaintiff-father lacked evidence to show a change in either parties’ financial circumstances or comply with the requisite documentation, the court affirmed denial of his modification motion.