Burden of Proof Not Met
The standard for modification due to cohabitation was not met where former spouse’s roommate made only one contribution toward household expenses, the couple did not have a joint checking account and did not commingle funds in any manner, wife’s cohabitation with roommate did not affect her need for support, maintenance payments were not used to support roommate, couple seldom ate together, wife never did his laundry, they only occasionally slept in the same bedroom, and wife’s cohabitation with roommate was not on a resident, continuing conjugal basis.
