To modify or change a spousal support Order, the party requesting the change must first prove that the Court has “continuing jurisdiction”. Second, the party requesting the change must then prove with evidence that there has been a substantial change in circumstances which were not anticipated at the time of the Divorce. Third, the party requesting the change must then prove by a preponderance of the evidence that the existing spousal support Order is no longer appropriate and reasonable. Decided November 4, 2010 in Burkart v. Burkart, 191 Ohio App.3d 169.
