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County of San Diego Dept. of Child Support Services v. Maki
San Diego County Department of Child Support Service (County) moved for an order to increase the child support obligation of Christopher Maki. The court order granted only an $11 per month increase, raising Christopher's support obligation to $636 per month, rather than raising his support obligation to the "guideline" amount of $953 per month. The court allowed Christopher two "hardship" deductions to reflect his financial burden to support children with whom he currently lived. County appeals, asserting the order must be reversed because the court did not make the requisite findings to support the hardship deductions and the omission was prejudicial.

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