Kumar v. Kumar, 2016 Va. App. LEXIS 301 (November 8, 2016)
A trial court declined to incorporate a portion of the parties' PSA related to child support, which imposed an obligation of support on husband prior to the entry of the final order, because the husband had fully complied with the pendente lite order, which required significant financial expenditure from husband for benefit of wife and children. The Court of Appeals upheld the decision of trial court and found that trial court did not change any substantive provisions of the PSA and held ยง 20-109.1 provides a trial court with discretion to incorporate a PSA or "provisions thereof'.