The DC Court of Appeals in Mazza v. Hollis, analyzed and addressed implications of a divorce settlement agreement with a child support clause merged but not incorporated into the final decree of divorce. Factually, Mazza and Hollis were divorced in Georgia via a settlement agreement. Thereafter, Hollis moved to Washington, D.C. with the child and registered the divorce decree in the Superior Court of the District of Columbia. Mazza later filed a Motion to Modify Custody and Child Support seeking a reduction in the amount of his monthly support obligation because of a substantial and material change in circumstances. The
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