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to conclude that the unallocated payments must terminate on the
death of the payee spouse as required by section 71(b)(1)(D).
Under the UDMA, child support and spousal maintenance must
be separately stated in a final divorce decree. See In re Huff,
834 P.2d 244, 248 (Colo. 1992) (error to incorporate an award of
attorney's fees into a maintenance award, because under the UDMA,
the district court is required to make separate orders regarding
each element of a dissolution order). Consequently, it appears
that unallocated family support payments may be used only in a
written separation agreement or in temporary orders.
Since the Temporary Orders did not require Mr. Lovejoy to
make separate maintenance and child support payments under the
provisions of the UDMA dealing expressly with those types of
payments, we conclude that the State court intended for the
unallocated payments to be governed by the express terms of the
Temporary Orders and the provisions of the UDMA dealing with
temporary orders.
In this case, petitioners agreed to the unallocated family
support payments in a stipulation which was incorporated into
Temporary Orders. The Temporary Orders state that the
unallocated payments must continue "until further Order of
Court." Moreover, Colo. Rev. Stat. sec. 14-10-108(5)(c), dealing
with temporary orders and injunctions, provides, in pertinent
part, that a temporary order "Terminates when the final decree is
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