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Fourth Department – Maintenance modification: Gardner v. Zammit

New York State Supreme Court, Appellate Division, Fourth Judicial Department Maintenance modification Downward departure – Summary judgment – Standard Gardner v. Zammit CA 20-00192 Appealed from Supreme Court, Erie County Background: On a prior appeal, the Appellate Division determined that the separation and property settlement agreement between the plaintiff and the defendant’s decedent, which was incorporated but not merged into a ...