Liberatore v. Liberatore (97 A.D.3d 821, 2012)

Since, at the time the mother filed her objections, there was no “final order” of a Support Magistrate determining the mother’s petition for a downward modification of child support, her objections were premature (Family Ct Act § 439 [e]). To the extent that the mother challenges earlier child support orders, her objections were untimely (see Matter of Hodges v Hodges, 40 AD3d 639 [2007]). Skelos, J.P., Balkin, Lott and Miller, JJ., concur.