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Miguel v. Yue CA1/4
Joseph Miguel has filed consolidated appeals from two orders concerning his duty to pay child support to his ex-wife Katie Yue. One appeal challenges a 2016 order that denied Miguel’s motion to reduce the amount of support based on a reduction in his income and increase in Yue’s income. The second appeal challenges two 2017 orders, one approving a stipulated agreement to adjust the support level and the other quashing a subpoena for Yue’s financial records. We conclude that the 2016 order, although applying to only a limited time period, must be reversed and remanded because the trial court failed to address Miguel’s argument that his support for the period in question should be reduced because Yue’s income had increased. We find no error in the 2017 orders.

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