IN THE

ARIZONA COURT OF APPEALS

DIVISION TWO

IN RE THE MARRIAGE OF:

RICHARD S. DOUGALL,

Petitioner/Appellant,

AND

MYRNA R. DOUGALL,

Respondent/Appellee.

No. 2 CA-CV 2013-0056

Filed December 18, 2013

Appeal from the Superior Court in Pima County

No. D20074351

The Honorable Dean Christoffel, Judge Pro Tempore

DISMISSED IN PART; AFFIRMED IN PART;

VACATED IN PART

COUNSEL

David Lipartito, Tucson

Counsel for Petitioner/Appellant

OPINION

Presiding Judge Vásquez authored the decision of the Court, in 

which Chief Judge Howard and Judge Miller concurred.

V Á S Q U E Z, Presiding Judge:
DOUGALL V. DOUGALL

Opinion of the Court

2

¶1 In this domestic-relations case, appellant Richard 

Dougall appeals from the trial court’s post-dissolution-decree order 

for the payment of spousal maintenance arrearages to appellee 

Myrna Dougall and the denial of his subsequent motion for 

reconsideration challenging that order. The issue presented here is 

whether A.R.S. § 25-530 precludes a trial court from considering 

Veterans Administration (VA) disability benefits as income in 

determining the payment of arrearages on an award of spousal 

maintenance. We hold a court may consider such benefits in making 

that determination. For the reasons stated below, we dismiss in 

part, affirm in part, and vacate in part.1

Factual and Procedural Background

¶2 We view the evidence in the light most favorable to 

sustaining the trial court’s rulings. See In re Marriage of Yuro, 192 

Ariz. 568, ¶ 3, 968 P.2d 1053, 1055 (App. 1998). The parties’ marriage 

was dissolved in 2008. The dissolution decree ordered Richard to 

pay Myrna $750 per month in spousal maintenance. The court also 

awarded each of the parties one-half interest in two parcels of real 

property and ordered that Richard obtain appraisals of the 

properties and pay Myrna her share of the equity. On appeal, this 

court affirmed the spousal maintenance award and the division of 

community property and debts. In re Marriage of Dougall, No. 2 CA–

CV 2009–0058 (memorandum decision filed Feb. 10, 2010).

¶3 In 2011, the trial court entered two judgments against 

Richard for his failure to fulfill his obligations under the decree of 

dissolution. The first judgment for $5,000 represented the value of 

Myrna’s interest in one of the properties. The second judgment was 

for $4,745 in spousal maintenance arrearages. Effective August 2011, 

the court also reduced Richard’s spousal maintenance obligation to 

$500 per month. This court affirmed the spousal maintenance 

 

1Myrna has not filed an answering brief in this court. 

Although we may consider her failure to do so an admission of 

error, in our discretion, we decline to do so. See In re Marriage of

Diezsi, 201 Ariz. 524, ¶ 2, 38 P.3d 1189, 1190 (App. 2002).
DOUGALL V. DOUGALL

Opinion of the Court

3

modification. In re Marriage of Dougall, No. 2 CA–CV 2011–0182 

(memorandum decision filed May 17, 2012).

¶4 In August 2012, Myrna filed petitions to enforce the two 

judgments, claiming Richard “ha[d] made no efforts to pay.” In 

response, Richard filed a memorandum seeking credits against the 

judgments for debts he had paid on behalf of Myrna and for a loan 

and vehicle he had given to her. After a hearing, the trial court 

entered its minute entry order on December 11, 2012, finding 

Richard in contempt but concluding he could purge himself of the 

contempt by paying, in addition to the $500 per month in current 

spousal maintenance, $200 per month toward the judgment for 

arrearages until paid in full.2 The court entered a separate incomewithholding order of $200 per month directed at Richard’s VA 

disability benefits and also denied his requests for offsets.

¶5 On January 4, 2013, Richard filed a combined “motion 

for new trial/motion to reconsider/motion for stay.” After a 

hearing, the court denied the motion by minute entry order entered 

February 8, 2013. However, at Richard’s request, the court modified 

its arrearages order by reducing the $200 payment to $100 per 

month for three months, then increasing it to $220 per month for 

fifteen months, and reinstating the $200 amount thereafter. This 

appeal followed.

Discussion

I. Appellate Jurisdiction

¶6 According to his notice of appeal, Richard is 

challenging the trial court’s December 11, 2012 and February 8, 2013 

orders. Although Richard contends we have jurisdiction pursuant 

to A.R.S. §§ 12-120.21 and 12-2101, we have an independent duty to 

review our jurisdiction and, if lacking, to dismiss the appeal. See In 

re Marriage of Flores & Martinez, 231 Ariz. 18, ¶ 6, 289 P.3d 946, 948 

 

2Although the trial court’s December 11, 2012 minute entry 

order referred to the $5,000 judgment and the court refused to give 

Richard any credits against it, the court did not enter any orders 

relating to that judgment.
DOUGALL V. DOUGALL

Opinion of the Court

4

(App. 2012). “We have no authority to entertain an appeal over 

which we do not have jurisdiction.” In re Marriage of Johnson & 

Gravino, 231 Ariz. 228, ¶ 5, 293 P.3d 504, 506 (App. 2012).

¶7 Generally, a notice of appeal must be filed no later than 

thirty days after entry of the judgment or order from which the 

appeal is taken. Ariz. R. Civ. App. P. 9(a); Wilkinson v. Fabry, 177 

Ariz. 506, 506, 869 P.2d 182, 182 (App. 1992). “[T]he timely filing of 

a notice of appeal is a jurisdictional prerequisite to appellate 

review.” In re Marriage of Gray, 144 Ariz. 89, 90, 695 P.2d 1127, 1128 

(1985). However, Rule 9(b), Ariz. R. Civ. App. P., provides an 

extension of time for filing a notice of appeal when certain motions 

are “timely filed” with the trial court. These time-extending motions 

include a motion for a new trial pursuant to Rule 83(A), Ariz. R. 

Fam. Law P., and a motion to alter or amend the judgment pursuant 

to Rule 84, Ariz. R. Fam. Law P. See Ariz. R. Civ. App. P. 9(b)(3), (4). 

Such motions must be filed not later than fifteen days after entry of 

the judgment. Ariz. R. Fam. Law P. 83(D)(1), 84. And when they are

not timely filed, a trial court does not have jurisdiction to address 

them, see Mark Lighting Fixture Co. v. Gen. Elec. Supply Co., 155 Ariz. 

27, 32, 745 P.2d 85, 90 (1987), and they do not extend the time for an 

appeal, see Edwards v. Young, 107 Ariz. 283, 285, 486 P.2d 181, 183 

(1971).

¶8 Here, Richard filed his notice of appeal from both the 

December 11 and February 8 orders on March 4, 2013. Thus, his 

notice of appeal as to the December 11 order was filed well beyond 

the thirty-day requirement of Rule 9(a), Ariz. R. Civ. App. P.

3

 

3The December 11 order also included a finding that Richard 

was in contempt of court. “[C]ontempt orders are unappealable 

unless the substance or effect of the order in question—beyond 

including a ‘finding[] of contempt,’—qualifies the order as one of 

those made appealable pursuant to § 12-2101.” Green v. Lisa Frank, 

Inc., 221 Ariz. 138, ¶ 21, 211 P.3d 16, 26 (App. 2009), quoting State v. 

Mulligan, 126 Ariz. 210, 216, 613 P.2d 1266, 1272 (1980). Therefore, 

even assuming the December 11 order was appealable because it 

went beyond a finding of contempt, we nevertheless lack 
DOUGALL V. DOUGALL

Opinion of the Court

5

Richard’s motion for a new trial constitutes a time-extending motion 

under Rule 9(b), Ariz. R. Civ. App. P., because he requested a new 

trial and “reconsideration, alteration, and/or amendment” pursuant 

to Rules 83 and 84, Ariz. R. Fam. Law P. However, the motion was 

not timely filed because it was filed more than fifteen days after 

entry of the December 11 order. See Ariz. R. Fam. Law P. 83(D)(1), 

84. We thus do not have jurisdiction to consider Richard’s appeal 

directly challenging the December 11 order.

4 See Edwards, 107 Ariz. 

at 285, 486 P.2d at 183.

¶9 However, Richard also appeals from the trial court’s 

February 8 order denying his “motion for a new trial/motion for 

reconsideration/motion for stay,” pursuant to Rule 85(C), Ariz. R. 

Fam. Law P. The denial of a Rule 85(C) motion is appealable as a 

“special order made after final judgment.” A.R.S. § 12-2101(A)(2); 

see M & M Auto Storage Pool, Inc. v. Chem. Waste Mgmt., Inc., 164 Ariz. 

139, 141, 791 P.2d 665, 667 (App. 1990) (discussing comparable 

Rule 60(c), Ariz. R. Civ. P.);

5 In re Marriage of Dorman & Cabrera, 198 

Ariz. 298, ¶ 3, 9 P.3d 329, 331 (App. 2000). And, to the extent the 

motion was based on Rule 85(C), it was timely filed. See Ariz. R. 

Fam. Law P. 85(C)(2); see also Duckstein v. Wolf, 230 Ariz. 227, ¶ 9, 282 

P.3d 428, 432 (App. 2012). We thus have jurisdiction to address the 

court’s denial of Richard’s Rule 85(C) motion.

 

jurisdiction over Richard’s appeal from this order for the reasons 

stated above.

4We therefore do not address Richard’s claims directly 

challenging the December 11 order, including his argument that the 

trial court erred by not offsetting the judgments with payments he 

made to or on behalf of Myrna. See Goglia v. Bodnar, 156 Ariz. 12, 16, 

749 P.2d 921, 925 (App. 1987) (review restricted to questions raised 

in Rule 60(c), Ariz. R. Civ. P., motion).

5“Wherever the language in [the Arizona Rules of Family Law 

Procedure] is substantially the same as the language in other 

statewide rules, the case law interpreting that language will apply to 

these rules.” Ariz. R. Fam. Law P. 1 cmt. Compare Ariz. R. Fam. Law 

P. 85(C), with Ariz. R. Civ. P. 60(c).
DOUGALL V. DOUGALL

Opinion of the Court

6

II. Denial of Rule 85(C) Motion

A. Trial Court Did Not Exceed Jurisdiction

¶10 When the trial court modified Richard’s spousal 

maintenance obligation in 2011, it stated that pursuant to § 25-530 it 

did not consider Richard’s VA disability benefits. But at the 

December 2012 hearing on Myrna’s petition for enforcement of 

spousal maintenance, the court did consider those benefits when it 

ordered Richard to pay an additional $200 per month toward 

spousal maintenance arrearages. The court based its December 11, 

2012 order on testimony that Richard’s total income was $3,918 per 

month, including $1,245 in social security and $2,673 in VA 

disability benefits. In setting the $200 amount, the court noted that, 

after paying the $500 spousal maintenance obligation, Richard 

“continues to have $3,400 of income available to him.”

¶11 Pursuant to Rule 85(C)(1)(d), Richard argues the trial 

court’s December 11 “order is void, outside the [c]ourt’s jurisdiction, 

and must be vacated.”6 He contends that, pursuant to 38 U.S.C. 

§ 5301, the court had no authority to require him to pay spousal 

maintenance arrearages, directly or indirectly, from his VA disability 

benefits. Citing § 25-530 and Downing v. Downing, 228 Ariz. 298, 265 

P.3d 1097 (App. 2011), he further maintains the court could not even 

consider those benefits when determining the amount of the 

monthly arrearages payment. We review the denial of a Rule 85(C) 

motion for relief from judgment for an abuse of discretion. Fry v. 

Garcia, 213 Ariz. 70, ¶ 7, 138 P.3d 1197, 1199 (App. 2006). An abuse 

of discretion occurs when a trial court commits an error of law in 

exercising its discretion. Fuentes v. Fuentes, 209 Ariz. 51, ¶ 23, 97 

P.3d 876, 881 (App. 2004).

¶12 Although Rule 85(C)(1)(d) provides an avenue for 

challenging a void judgment, we disagree with the underlying 

 

6On appeal, Richard does not expressly cite Rule 85(C) as a 

basis for his argument. However, he did so below, and we 

understand his argument on appeal to be substantially the same; we 

thus address it accordingly.
DOUGALL V. DOUGALL

Opinion of the Court

7

premise of Richard’s argument—that a trial court exceeds its 

jurisdiction and thus renders a void judgment by considering VA 

disability benefits in violation of § 25-530. The word “void” often is

misused, Auman v. Auman, 134 Ariz. 40, 42, 653 P.2d 688, 690 (1982), 

as is the word “jurisdiction,” Marvin Johnson, P.C. v. Myers, 184 Ariz. 

98, 101, 907 P.2d 67, 70 (1995). “A judgment or order is ‘void’ if the 

court entering it lacked jurisdiction: (1) over the subject matter, (2) 

over the person involved, or (3) to render the particular judgment or 

order entered.” Martin v. Martin, 182 Ariz. 11, 15, 893 P.2d 11, 15

(App. 1994). “If a judgment or order is void, the trial court has no 

discretion but to vacate it.” Id. at 14, 893 P.2d at 14. By contrast, a

judgment or order is voidable “when the trial court has subject 

matter jurisdiction but errs in issuing an order.” State v. Bryant, 219 

Ariz. 514, ¶ 14, 200 P.3d 1011, 1015 (App. 2008). A voidable 

judgment or order has “all the ordinary attributes of a valid 

judgment [or order] until it is reversed or vacated.” State v. Cramer, 

192 Ariz. 150, ¶ 16, 962 P.2d 224, 227 (App. 1998).

¶13 Here, the trial court had subject matter jurisdiction to 

decide issues involving spousal maintenance, including arrearages. 

See A.R.S. § 25-552(A). And even if, as Richard argues, the court 

violated § 25-530 by considering his VA disability benefits, such an 

error “fall[s] short of undermining jurisdiction so as to render that 

[order] void and subject to vacation” under Rule 85(C)(1)(d). 

Cockerham v. Zikratch, 127 Ariz. 230, 235, 619 P.2d 739, 744 (1980). In 

any event, for the reasons that follow, we find no such statutory

violation here.7

B. Federal Law and Consideration of VA Disability Benefits

¶14 In relevant part, 38 U.S.C. § 5301(a)(1), dealing with 

veteran benefits, provides:

 

7“Because we conclude that the issue presented here, 

involving the interpretation of [§ 25-530], is an issue of law and a 

matter of statewide importance, we exercise our discretion to 

address the merits of [Richard’s] claim.” Searchtoppers.com, L.L.C. v. 

TrustCash LLC, 231 Ariz. 236, ¶ 8, 293 P.3d 512, 514 (App. 2012).
DOUGALL V. DOUGALL

Opinion of the Court

8

Payments of benefits due or to become due 

under any law administered by the 

Secretary shall not be assignable except to 

the extent specifically authorized by law, 

and such payments made to, or on account 

of, a beneficiary shall be exempt from 

taxation, shall be exempt from the claim of 

creditors, and shall not be liable to 

attachment, levy, or seizure by or under 

any legal or equitable process whatever, 

either before or after receipt by the 

beneficiary.

¶15 In Rose v. Rose, 481 U.S. 619, 621-22 (1987), the Supreme 

Court addressed the scope of the federal statute in considering 

whether a Tennessee state court had jurisdiction to hold a veteran in 

contempt for nonpayment of child support when the veteran’s only 

means of satisfying the obligation was chapter 38 service-connected 

disability benefits. The veteran argued that various federal laws, 

including 38 U.S.C. § 5301(a)(1),

8 evinced a Congressional intent to 

preempt state statutes that give state courts jurisdiction over 

veterans’ disability benefits. Rose, 481 U.S. at 625, 630. According to 

the Court, 38 U.S.C. § 5301 has “two purposes: [1] to ‘avoid the 

possibility of the Veterans’ Administration . . . being placed in the 

position of a collection agency,’” and [2] “to ‘prevent the deprivation 

and depletion of the means of subsistence of veterans dependent 

upon these benefits as the main source of their income.’” Rose, 481 

U.S. at 630, quoting S. Rep. No. 94-1243, at 147-48 (1976). The Court 

determined that neither of these purposes was “constrained by 

allowing the state court . . . to hold [the veteran] in contempt for 

failing to pay child support.” Id. Specifically, the Court noted that 

veteran disability benefits “are intended to ‘provide reasonable and 

adequate compensation for disabled veterans and their families.’” Id.,

quoting S. Rep. No. 98–604, at 24 (1984) (emphasis in Rose). The 

Court thus concluded that 38 U.S.C. § 5301(a)(1) “does not extend to 

 

8Congress renumbered 38 U.S.C. § 3101 to 38 U.S.C. § 5301. 

Department of Veterans Affairs Health-Care Personnel Act of 1991, 

Pub. L. No. 102-40, 105 Stat. 187.
DOUGALL V. DOUGALL

Opinion of the Court

9

protect a veteran’s disability benefits from seizure where the veteran 

invokes that provision to avoid an otherwise valid order of child 

support.”9 Rose, 481 U.S. at 634.

¶16 The Court also rejected the veteran’s argument based on 

other federal laws and affirmed the contempt finding. Id. at 636. In 

doing so, the Court stated that, even though a veteran’s disability 

benefits may be “exempt from garnishment or attachment while in 

the hands of the Administrator, we are not persuaded that once 

these funds are delivered to the veteran a state court cannot require 

that veteran to use them to satisfy an order of child support.” Id. at 

635.

¶17 After Rose, state courts generally have concluded that, 

although 38 U.S.C. § 5301(a)(1) “would preclude an assignment or 

apportionment of [a] veteran[’s] disability benefits, it does not 

preclude consideration of disability benefits by a trial court as a 

source of income upon which an award of alimony may be based.

”10 

Repash v. Repash, 528 A.2d 744, 745 (Vt. 1987); see also Urbaniak v. 

Urbaniak, 807 N.W.2d 621, ¶¶ 18, 20 (S.D. 2011); Zickerfoose v. 

Zickerfoose, 724 S.E.2d 312, 317-18 (W. Va. 2012). This court has 

 

9We are unpersuaded by Richard’s argument that Rose is 

limited to child support and “does not extend to spousal 

maintenance.” As noted above, Rose discusses “family support 

obligations” generally; the Court did not expressly limit its analysis 

to child support. 481 U.S. at 632. And other state courts have 

extended Rose’s reasoning to spousal maintenance. See In re 

Marriage of Anderson, 522 N.W.2d 99, 102 (Iowa Ct. App. 1994) (“It is 

clear veteran’s benefits are not solely for the benefit of the veteran, 

but for his family as well.”). Richard’s reliance on Mansell v. Mansell, 

490 U.S. 581 (1989), also is unavailing. There the Court confirmed 

that federal law precludes division of VA disability benefits as 

community property, it said nothing about considering those 

benefits in the context of spousal maintenance. Id. at 594-95.

10In 1997, Congress provided for garnishment of serviceconnected disability benefits for child support and alimony

obligations if the veteran waived a portion of his or her military 

retired pay to obtain the benefits. See 42 U.S.C. § 659(h)(1)(A)(ii)(V).
DOUGALL V. DOUGALL

Opinion of the Court

10

reached the same conclusion. Cf. In re Marriage of Priessman, 228 

Ariz. 336, 340, 266 P.3d 362, 366 (App. 2011) (affirming trial court’s 

consideration of such benefits in modifying spousal maintenance). 

However, in July 2010, the Arizona legislature enacted § 25-530, 

which provides: “In determining whether to award spousal 

maintenance or the amount of any award of spousal maintenance, 

the court shall not consider any federal disability benefits awarded 

to the other spouse for service-connected disabilities pursuant to 38 

United States Code chapter 11.”

C. Applicability of § 25-530 to Arrearages

¶18 We therefore turn to whether § 25-530 precludes a trial 

court from considering VA disability benefits in ordering the 

payment of arrearages on a spousal maintenance award. Because 

this issue requires us to interpret § 25-530, our review is de novo. 

See Danielson v. Evans, 201 Ariz. 401, ¶ 13, 36 P.3d 749, 754 (App. 

2001). Our primary goal in interpreting statutes is to determine and 

give effect to the legislature’s intent. Simpson v. Simpson, 224 Ariz. 

224, ¶ 6, 229 P.3d 236, 237 (App. 2010). “The best indicator of 

legislative intent is the plain language of the statute,” id., and “we 

will give terms ‘their ordinary meanings, unless the legislature has 

provided a specific definition or the context of the statute indicates a 

term carries a special meaning.’” Kessen v. Stewart, 195 Ariz. 488, 

¶ 6, 990 P.2d 689, 692 (App. 1999), quoting Wells Fargo Credit Corp. v. 

Tolliver, 183 Ariz. 343, 345, 903 P.2d 1101, 1103 (App. 1995). When 

the language of a statute is clear and unambiguous, we apply its 

plain meaning without resorting to other methods of statutory 

interpretation. Merrill v. Merrill, 230 Ariz. 369, ¶ 27, 284 P.3d 880, 

887 (App. 2012).

¶19 According to the plain language of the statute, § 25-530

applies when a court is determining “whether to award spousal 

maintenance” or “the amount of any award of spousal 

maintenance.” In Downing, this court held the statute also applies to 

a modification of spousal maintenance. 228 Ariz. 298, ¶¶ 6, 12, 265 

P.3d at 1099, 1100. But here, the trial court was not making a 

determination “whether to award spousal maintenance” or “the 

amount of any award.” Indeed those determinations already had 

been made and, as noted above, were affirmed by this court on 
DOUGALL V. DOUGALL

Opinion of the Court

11

appeal.11 Nor was the trial court modifying the amount of spousal 

maintenance. Rather, the current proceedings arose from Richard’s 

failure to pay arrearages on spousal maintenance previously 

awarded. See A.R.S. § 25-500(1) (defining “[a]rrearage” as “the total 

unpaid support owed”). Thus, we conclude that § 25-530 does not 

preclude a trial court from considering VA disability benefits in 

determining the payment of arrearages on an award of spousal 

maintenance. The trial court therefore did not err by considering 

Richard’s VA disability benefits in determining his ability to pay the 

arrearages.

¶20 Richard nonetheless argues that the “prohibition [under 

§ 25-530] logically extends to an arrears payment order.” He reasons 

that § 25-530 coupled with A.R.S. § 25-318.01 “evince a public policy 

to protect the benefits of disabled veterans from having these 

benefits taken to satisfy property division or spousal maintenance 

orders.”12 But, “absent a clear indication of legislative intent to the 

contrary, we are reluctant to construe the words of a statute to mean 

something other than what they plainly state.” Canon Sch. Dist. No. 

50 v. W.E.S. Constr. Co., 177 Ariz. 526, 529, 869 P.2d 500, 503 (1994); 

see also City of Tempe v. Fleming, 168 Ariz. 454, 457, 815 P.2d 1, 4 

(App. 1991) (“[W]e will not read into a statute something which is 

not within the manifest intent of the legislature as indicated by the 

statute itself.”). And, we decline to do so here. Section 25-318.01

applies to the division of property and thus does not apply in this 

case.

 

11Section 25-530 became effective in July 2010, before the initial 

spousal maintenance award in this case. However, because we 

conclude the statute does not apply to a trial court’s determination 

of arrearages, the effective date is not determinative of the issue 

presented here.

12Section 25-318.01 provides, in part: “In making a disposition 

of property pursuant to section 25-318 or 25-327, a court shall not . . . 

[c]onsider any federal disability benefits awarded to a veteran for 

service-connected disabilities pursuant to 38 United States Code 

chapter 11.” The legislature enacted § 25-318.01 at the same time as 

§ 25-530. 2010 Ariz. Sess. Laws, ch. 70, §§ 2-3.
DOUGALL V. DOUGALL

Opinion of the Court

12

¶21 Lastly, we address Richard’s contention that the trial 

court erred by entering an income-withholding order against his VA 

disability benefits. The court’s order directed the VA to withhold 

$200 per month from Richard’s disability benefits, but further stated, 

“[i]n the event that the Veteran’s Administration does not honor the 

income withholding order[,] it shall be [Richard]’s responsibility to 

pay.” At the February 5 hearing, the court noted “the VA will not 

withhold any of [Richard]’s funds for spousal maintenance arrears” 

and then ordered Richard to make the payments directly. Although 

the court indicated it was not enforcing it, we vacate the incomewithholding order directed at Richard’s VA disability benefits. See 

also 38 U.S.C. § 5301(a)(1); Danielson, 201 Ariz. 401, ¶ 33, 36 P.3d at 

758. Notably, the court ordered Richard “to make . . . the 

payments,” without specifying the source of the funds. After the 

$500 spousal maintenance garnishment, Richard receives $740 in 

social security, in addition to the $2,673 in VA disability benefits. He 

could use any portion of those funds to pay $200 per month toward 

the judgment for arrearages. See Danielson, 201 Ariz. 401, ¶ 19, 36 

P.3d at 755; Merrill, 230 Ariz. 369, ¶ 29, 284 P.3d at 887.

Conclusion

¶22 For the reasons stated above, we dismiss Richard’s 

appeal directly challenging the trial court’s December 11, 2012 order, 

vacate the income-withholding order directed at Richard’s VA 

disability benefits, but otherwise affirm the trial court’s orders.