
    CIRCUIT COURT OF FAIRFAX COUNTY
    Park v. Park
    July 9, 1990
    Case No. (Chancery) 111266
   By JUDGE THOMAS A. FORTKORT

The court does retain the power to modify the pendente lite decree. The parties may have entered into a contract by agreeing to a consent order, nevertheless modification of this type of agreement is not prohibited by § 20-109. Section 20-109 is limited to final dispositions of alimony and support and not to support pendente lite. The companion Section 20-109.1 also speaks to a final decree.

The decree pendente lite may be modified by the court upon a showing of a change of circumstances.  