Appellate Division of the Supreme Court of the State of New York March 19, 1996 (Berger v. Berger)

Defendant’s claim of a substantial change in circumstances being unsupported by any evidence, except a letter from the New Jersey welfare authorities notifying him of a contemplated rate reduction in the sums payable to his business operations, which communication was available to him, but unsubmitted on the original pendente lite motion. Clearly this is insufficient.