The Court of Appeals in Wilson v. Craig, highlighted that child custody and support can be modifying after the final decree of divorce and execution of a separation agreement essentially nullifying the agreement. Parties had reached a comprehensive separation agreement, which was incorporated by reference but not merged into the final divorce decree addressing property distribution, child custody, and child support.  The child custody provision of the agreement called for joint legal and physical custody of the children. Ms. Craig subsequently filed for modification of child custody agreement requesting sole physical and legal custody of the children.  The trial court
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