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4. That subsequent to the entry of the Judgment For
Dissolution Of Marriage there has been a substantial change
of circumstances in:
A. That the eldest child * * * [CR] is emancipated.
B. That there has been a change of custody from
Respondent [Ms. Randich] to Petitioner [Mr. Randich] as
to the minor child * * * [LR] pursuant to an Order
entered July 20, 2000.
WHEREFORE, Petitioner, [Mr. Randich] and by his attorney,
BRUCE D. FALK, respectfully request this Honorable Court as
follows:
A. For an Order modifying the unallocated support
obligation commensurate with the change of
circumstances of the parties.
D. For such other and further relief as the Court may
deem appropriate.
On March 5, 2001, an order relating to the September 2000
motion for modification of support was entered by the circuit
court. In this order, the circuit court found that the “change
of custody of minor child * * * [LR] constitutes a change of
circumstances regarding support”. However, the circuit court did
not modify the unallocated family support in this order.
On March 14, 2001, Mr. Randich filed with the circuit court
a letter addressed to the judge presiding over petitioners’
divorce case and a brief and argument on behalf of petitioner
Steven Randich in support of the September 2000 motion for
modification of support. The brief states, in pertinent part:
Petitioner [Mr. Randich] has filed a motion for
modification of child support. Respondent [Ms. Randich] has
filed a motion concerning payment of college expenses. The
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