Appellate Division of the Supreme Court of the State of New York September 27, 2011 (DeCries v. DeVries)

In the parties’ judgment of divorce dated May 27, 2005, the father’s weekly support obligation was set at $1,702.75. In January 2010, the Orange County Support Collection Unit (hereinafter the SCU) issued a notice of cost-of-living adjustment (hereinafter COLA) order proposing to increase the father’s weekly support obligation to $1,928.