Delaine Brian Laski v. Jennifer Rene Laski
CourtCourt of Appeals of Wisconsin
Date FiledNovember 10, 2026
Docket2025AP001411
StatusUnpublished
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Full Opinion
COURT OF APPEALS
DECISION NOTICE
DATED AND FILED This opinion is subject to further editing. If
published, the official version will appear in
the bound volume of the Official Reports.
November 10, 2026
A party may file with the Supreme Court a
Samuel A. Christensen petition to review an adverse decision by the
Clerk of Court of Appeals Court of Appeals. See WIS. STAT. § 808.10
and RULE 809.62.
Appeal No. 2025AP1411 Cir. Ct. No. 2023FA50
STATE OF WISCONSIN IN COURT OF APPEALS
DISTRICT III
IN RE THE MARRIAGE OF:
DELAINE BRIAN LASKI,
PETITIONER-RESPONDENT,
V.
JENNIFER RENE LASKI,
RESPONDENT-APPELLANT.
APPEAL from an order of the circuit court for Douglas County:
GEORGE L. GLONEK, Judge. Affirmed.
Before Stark, P.J., Hruz, and Gill, JJ.
Per curiam opinions may not be cited in any court of this state as precedent
or authority, except for the limited purposes specified in WIS. STAT. RULE 809.23(3).
No. 2025AP1411
¶1 PER CURIAM. Jennifer Laski, pro se, appeals from a circuit court
order denying her motion to modify or reconsider the terms of the parties’
judgment of divorce pursuant to WIS. STAT. §§ 806.07 and 767.59 (2023-24).1
Jennifer argues that the court erroneously exercised its discretion by failing to
modify its property division decision and maintenance award. Jennifer also argues
that the court erred by failing to order the return of her personal property. For the
reasons that follow, we reject Jennifer’s arguments and affirm.
BACKGROUND
¶2 Delaine Laski petitioned for divorce from Jennifer in March 2023.
The parties, who were both represented by counsel, reached a partial marital
settlement agreement. The agreement resolved the issues of custody and physical
placement of their minor child. The parties later reached a second partial marital
settlement agreement, whereby they agreed to a negotiated division of their
personal property. The remaining issues, including the division of marital
property and the awarding of maintenance, were addressed at a contested divorce
hearing.
¶3 In September 2024, following the contested divorce hearing, the
circuit court ordered the equal division of the marital property, and it adopted the
parties’ partial marital settlement agreements. Relevant to this appeal, the court
found that a Gordon, Wisconsin, property gifted to Jennifer and her four siblings
was marital property because the parties had refinanced the property to purchase
Jennifer’s siblings’ interests, and Jennifer had thereafter quitclaim deeded the
1
All references to the Wisconsin Statutes are to the 2023-24 version.
2
No. 2025AP1411
property to herself and Delaine to be held jointly as survivorship marital property.
For similar reasons, the court also denied Jennifer’s request that she be
individually awarded an “$80,000.00 interest” in the Gordon property.
¶4 As to maintenance, Jennifer requested that the circuit court award
her $800 per month for nine years. According to the court, Jennifer’s calculation
was “[a]pparently” “based merely upon [her] calculation of one-half of the
difference between the parties’ respective incomes. Moreover, the requested
length of maintenance for nine[ ]years is based merely upon one-half of the length
of the marriage.” After applying the statutory factors under WIS. STAT. § 767.56,
the court awarded $400 per month in maintenance to Jennifer until their minor
child presumably graduated from high school (when Jennifer’s child support
payments to Delaine would likely end).
¶5 As to the marital property, the circuit court ordered that the parties
either notify the court of an equalization payment agreement or file their
respective proposals if they could not agree. Afterward, Jennifer’s attorney
informed the court that the parties could not agree on how to equalize the marital
estate. Jennifer’s attorney proposed that Delaine’s retirement be split (via a
qualified domestic relations order (QDRO)) and that he pay Jennifer over $26,500
through a cashier’s check to equalize the estate. In response, Delaine’s attorney
agreed to the QDRO but proposed that Delaine pay Jennifer $25,150 to equalize
the marital estate, which accounted for Delaine accepting more of the marital debt
than Jennifer. Because Delaine did not have $25,150 in liquid assets, his attorney
requested that the court provide Jennifer additional interest in the QDRO. The
court adopted Delaine’s proposal, finding that it was “the fairest way to equalize
the estate,” given that Delaine did not have “liquid assets such that [he] would be
able to pay [Jennifer] that substantial amount in cash.”
3
No. 2025AP1411
¶6 In October 2024, the circuit court entered a judgment granting the
divorce and incorporating by reference the partial marital settlement agreements,
its September 2024 decision, and its equalization decision. Neither party appealed
the October 2024 divorce judgment.
¶7 Several months later, Jennifer filed a pro se motion using a standard
form, seeking, in pertinent part, revision of support and maintenance orders
pursuant to WIS. STAT. § 767.59. Attached to the standard form was a typed
document titled “Motion for Change or Reconsideration,” which cited both
§ 767.59 and WIS. STAT. § 806.07. (Formatting altered.) In the form portion of
her motion, Jennifer requested an increase to the maintenance award in an amount
“to be determined by the [circuit] court based on current income.” Jennifer also
checked an “Other change(s)” box and stated, “See attached.” Jennifer stated that
there had been a substantial change in circumstances because of “[a]ttorney
dereliction of duty,” and she asserted that the “QDRO was never executed,” that
she “face[d] taxes and penalties if paid this way,” and that she wanted, as an
alternative to the QDRO, the proceeds from “a piece of property” that Delaine was
selling.
¶8 In the attached document, Jennifer further explained that her debt “to
income ratio ha[d] changed significantly due to medical conditions.” In addition,
Jennifer stated that her previous counsel “failed to adequately investigate or
present relevant financial and evidentiary information, resulting in tax identity
issues and a mischaracterization of” the parties’ financial circumstances. Citing
WIS. STAT. § 806.07(1)(a) (allowing relief from a judgment based on mistake,
inadvertence, surprise, or excusable neglect), Jennifer argued that her “prior
attorney failed to raise critical defenses and failed to disclose or correct inaccurate
representations of [Jennifer’s] financial situation.” For example, according to
4
No. 2025AP1411
Jennifer, her attorney “[n]eglected to obtain and present [her] medical evidence
affecting financial and property division” and “[n]eglected to properly challenge
[Delaine]’s claims of inability to pay, despite evidence of available assets.”
¶9 Furthermore, citing WIS. STAT. § 806.07(1)(b) (allowing relief from
a judgment based on newly discovered evidence), Jennifer stated that she had
“since obtained financial and medical documents and information—including tax
records and assets for sale—that were not available or submitted during the initial
proceedings.” Jennifer also cited § 806.07(1)(g) (allowing relief from a judgment
that is no longer equitable) and (h) (allowing relief from a judgment for any other
reasons), and she argued that given her “financial hardship … and the adverse
effects of the judgment on the best interests of the minor child[], the continued
enforcement of the judgment is unjust and inequitable.”
¶10 The circuit court held an evidentiary hearing on Jennifer’s motion.
At the hearing, Jennifer clarified that she was not arguing that the court had made
a mistake during the divorce proceedings. Jennifer stated that her claims were
based on “mistakes that happened during the trial on [the] basis of [her] attorney.”
Jennifer also asserted, for the first time, that certain “personal property was never
returned.”
¶11 In a June 2025 order, the circuit court largely denied Jennifer’s
motion.2 First, the court held that to the extent Jennifer was seeking
reconsideration under WIS. STAT. § 805.17(3), her motion was untimely because it
2
The circuit court found that the amount of the equalization payment had originally been
miscalculated by $746.50, so it ordered, pursuant to WIS. STAT. § 806.07(1)(h), that Delaine
make a cash payment to Jennifer in that amount.
5
No. 2025AP1411
was filed more than 20 days after entry of the court’s October 2024 divorce
judgment. See § 805.17(3).
¶12 The circuit court next determined that Jennifer was not entitled to
relief under WIS. STAT. § 806.07. The court concluded that “most of the evidence
and documents” that Jennifer presented to the court (“including a vast number of
medical records”) did not constitute newly discovered evidence under
§ 806.07(1)(b) because the documents were in existence at the time of the
contested divorce hearing, and Jennifer “would have been aware of the[ir]
existence.” Moreover, because Jennifer was still gainfully employed, the court
found that none of the additional medical records she submitted would have
changed its analysis of property division or maintenance. The court further stated
that because Jennifer’s income had increased, while her expenses had decreased,
since the time of the contested hearing, it was “difficult to understand how this
most recent financial information would be of any particular benefit to [Jennifer]
with regard to this Court’s prior decisions regarding … maintenance or property
division.”
¶13 The circuit court also concluded that, as Jennifer’s motion related to
her attorney’s performance, “neglect of an attorney” “is no ground for relief in
equity.” Regarding the QDRO and Delaine’s ability to pay the equalization
amount, the court denied Jennifer’s motion for the reasons stated in its prior
equalization decision, noting that Jennifer’s counsel did, in fact, request that
Delaine pay the equalization via cashier’s check. Regardless, according to the
court, the financial information Jennifer sought to admit constituted
“newly-created evidence, not newly-discovered evidence.” As it pertained to the
personal property not returned, the court ordered that the parties “cooperate with
one another in making final arrangements for [Jennifer] to retrieve her remaining
6
No. 2025AP1411
personal property … within 30 days” of the hearing. The court stated that
“[f]ailure to comply with” the court’s order “could constitute contempt of court.”3
¶14 Finally, the circuit court denied Jennifer’s motion to modify
maintenance under WIS. STAT. § 767.59(1f)(a), stating that there had not been a
substantial change in circumstances.
¶15 Jennifer now appeals from the circuit court’s June 2025 order.
DISCUSSION
¶16 On appeal, Jennifer argues that the circuit court erred in the
following respects: (1) by “adopting an incorrect QDRO amount, failing to
account for updated financial disclosures …, and failing to issue the equalization
payment separately”; (2) by treating the Gordon property as marital property and
not awarding her an $80,000 interest in the property; (3) by “denying enforcement
of the property return order”; and (4) by failing to change the maintenance award
“despite undisputed financial hardship.” (Formatting altered.)
I. QDRO and the Gordon property
¶17 As an initial matter, we note that Jennifer does not adequately rely
on WIS. STAT. § 806.07 for any of the claims she makes on appeal with respect to
the circuit court’s denial of her motion to modify the property division. The court
correctly recognized that although property division in a divorce is not subject to a
circuit court’s continuing jurisdiction and may not be modified based on a change
3
At the evidentiary hearing, the circuit court likewise stated that if Delaine was refusing
to allow Jennifer to retrieve her personal property, in violation of the court’s previous rulings,
then Jennifer could “file a motion for contempt, and we’ll address it at a contempt hearing.”
7
No. 2025AP1411
of circumstances under WIS. STAT. § 767.59, § 806.07 “gives the court
discretionary authority to grant relief from the judgment.” See Franke v. Franke,
2004 WI 8, ¶21, 268 Wis. 2d 360, 674 N.W.2d 832 (citation omitted).
¶18 In fact, Jennifer’s arguments in the circuit court and in this court
appear, at times, to challenge the court’s October 2024 judgment, not its June 2025
order.4 For example, Jennifer states on appeal that the court erred by “rolling
the … equalization payment” “into the QDRO rather than requiring a separate,
non-taxable cash payment as contemplated under WIS. STAT. § 767.61(3).”
Jennifer further contends that the record from the contested divorce hearing
demonstrates that her $80,000 interest in the Gordon property should be
considered non-divisible and that the Gordon property was not marital property.
¶19 To the extent that Jennifer is attempting to directly challenge the
circuit court’s October 2024 judgment—as opposed to the court’s June 2025 order
rejecting her claims under WIS. STAT. § 806.07—with respect to the QDRO or the
Gordon property, we lack appellate jurisdiction to review that order in the absence
of a timely filed direct appeal, which Jennifer did not file, and we reject those
claims on this basis. See WIS. STAT. RULE 809.10(1)(e) (“The filing of a timely
notice of appeal is necessary to give the court jurisdiction over the appeal.”).
4
We pause to note that Delaine cites an authored but unpublished opinion in his brief on
appeal without any explicit indication that it is an unpublished opinion. While the opinion is
authored and citable for its persuasive value, see WIS. STAT. RULE 809.23(3)(b), Delaine failed to
file and serve a copy of the opinion, in violation of RULE 809.23(3)(c).
We further note that Jennifer cites to “Wochos v. Wochos, 2000 WI App 132” in her
reply brief. This court was unable to locate any such case.
8
No. 2025AP1411
¶20 Similarly, many of Jennifer’s claims relating to the property
division—particularly those premised on her former attorney’s alleged deficient
representation—while framed under WIS. STAT. § 806.07(1), are really arguments
that could have been, but were not, raised at the divorce stage of the proceedings
or on direct appeal from the circuit court’s October 2024 judgment. See Eau
Claire County v. Employers Ins. of Wausau, 146 Wis. 2d 101, 111, 430 N.W.2d
579 (Ct. App. 1988) (concluding that, under the circumstances of the case,
§ 806.07(1)(h) did “not authorize the trial court to essentially expand the time for
appeal when the time for such appeal had passed”). While § 806.07 may, under
certain narrow circumstances, be used as a means of seeking relief from a
judgment due to counsel’s unsatisfactory performance, Jennifer fails to
demonstrate that her attorney’s performance was so egregious or extreme as to
warrant relief or that the circuit court erroneously exercised its discretion by
denying such relief. See Village of Big Bend v. Anderson, 103 Wis. 2d 403, 407,
308 N.W.2d 887 (Ct. App. 1981). Accordingly, we reject Jennifer’s claims as
they relate to her attorney’s alleged deficient representation. See State v. Pettit,
171 Wis. 2d 627, 646, 492 N.W.2d 633 (Ct. App. 1992) (“We may decline to
review issues inadequately briefed.”).
¶21 More to our first point, Jennifer’s remaining arguments fail because
she does not explain how WIS. STAT. § 806.07 warrants relief. Jennifer did not
cite § 806.07 or the proper standard of review in her brief-in-chief. We recognize
that Jennifer is representing herself on appeal. However, despite Jennifer’s pro se
status, it remains her burden on appeal to demonstrate that the circuit court erred,
see Gaethke v. Pozder, 2017 WI App 38, ¶36, 376 Wis. 2d 448, 899 N.W.2d 381,
and it is well established that appellate courts “do not step out of [their] neutral
role to develop or construct arguments for parties,” see Doe 1 v. Madison Metro.
9
No. 2025AP1411
Sch. Dist., 2022 WI 65, ¶35, 403 Wis. 2d 369, 976 N.W.2d 584 (citation omitted);
see also Pettit, 171 Wis. 2d at 646-47. Pro se appellants “are bound by the same
rules that apply to attorneys on appeal,” and the “right to self-representation is
‘[not] a license not to comply with relevant rules of procedural and substantive
law.’” Waushara County v. Graf, 166 Wis. 2d 442, 452, 480 N.W.2d 16 (1992)
(alteration in original; citation omitted). Applying these principles here, we
conclude that Jennifer has failed to satisfy her burden of demonstrating that the
circuit court erroneously exercised its discretion by denying her motion to modify
the property division pursuant to § 806.07.5
¶22 Jennifer appears to contend that the circuit court erred by not relying
on Delaine’s June 2025 income and expenses as an update to his February 2024
financial disclosure statement when denying her motion to modify the property
division. According to Jennifer, “[b]y relying on outdated and incomplete data,
the court effectively undervalued marital assets, producing an inequitable property
division and QDRO allocation contrary to WIS. STAT. § 767.61(3) and the
principles of equitable distribution.” Similarly, Jennifer appears to argue that the
court erred by denying her motion to modify the property division based on
unforeseen tax consequences stemming from the QDRO. Jennifer further
contends that the court erred by failing to account for evidence demonstrating that
the Gordon property is now three parcels instead of a single parcel.
5
Moreover, to the extent Jennifer challenges the circuit court’s denial of her motion for
reconsideration, the court correctly observed that her motion was filed well beyond the 20-day
deadline set forth in WIS. STAT. § 805.17(3). Jennifer fails to develop any argument as to why
§ 805.17(3) should not apply to her motion for reconsideration. See State v. Pettit, 171 Wis. 2d
627, 646-47, 492 N.W.2d 633 (Ct. App. 1992).
10
No. 2025AP1411
¶23 Jennifer fails to explain how Delaine’s updated financial status
would entitle her to relief under WIS. STAT. § 806.07, particularly where Delaine’s
and Jennifer’s incomes had both increased modestly since the divorce judgment
was entered. Nor does Jennifer explain how § 806.07 would entitle her to relief on
the basis that the Gordon property is not a single parcel. Moreover, she does not
challenge the circuit court’s findings that the information she provided to the court
was not newly discovered evidence. Likewise, the tax consequences to each party
in a divorce are but one factor a circuit court considers at property division,
see WIS. STAT. § 767.61(3)(k), and Jennifer fails to develop an argument as to
why § 806.07 would entitle her to relief based on those consequences.6
¶24 Finally, Jennifer appears to argue that the circuit court failed to
amend its October 2024 judgment to reflect the $746.50 payment it ordered
Delaine to pay her as a correction to the equalization payment. We adopt
Delaine’s reasoning on this issue:
When the … court discovered that the amount of the
$25,150.92 equalization payment it had originally ordered
to be made through the QDRO was too low by $746.50, the
court rightfully and properly corrected its own error by
ordering Delaine to pay this sum directly to Jennifer within
30 days. By doing so, the … court did not need to revisit or
change its underlying order regarding the rest of the
equalization payment through the QDRO. Instead, the
court simply and efficiently ordered a separate additional
6
Jennifer is correct that a circuit court must be aware of the tax consequences of a
property division award. See Ondrasek v. Ondrasek, 126 Wis. 2d 469, 480, 377 N.W.2d 190 (Ct.
App. 1985). In her reply brief, and for the first time in this case, she cites 26 U.S.C.
§ 402(e)(1)(A) for the proposition that “distributions made pursuant to a QDRO are taxable to the
recipient,” and she asserts that “[t]he adverse tax consequences of this structure were not
reasonably apparent until implementation.” Because the circuit court was not presented with an
opportunity to adjudicate the applicability of § 402(e)(1)(A), and Delaine did not have a chance to
dispute its applicability on appeal, we conclude that Jennifer forfeited this argument. See Schill
v. Wisconsin Rapids Sch. Dist., 2010 WI 86, ¶45 n.21, 327 Wis. 2d 572, 786 N.W.2d 177.
11
No. 2025AP1411
payment of the missing $746.50, which made Jennifer
whole on the equalization issue. It is unclear from her brief
what Jennifer’s complaint is regarding the $746.50 issue.
In her reply brief, Jennifer fails to respond to Delaine’s summation of her
argument or his analysis of this issue; regardless, we conclude that the record
supports Delaine’s argument. Accordingly, we reject Jennifer’s claim as it relates
to the court’s correction of the equalization payment.
II. Property return order
¶25 Jennifer further argues that the circuit court erred by denying
enforcement of the parties’ second partial marital settlement agreement, whereby
they agreed to a negotiated division of their personal property. According to
Jennifer, Delaine has “failed to return numerous awarded items.”7 Jennifer
therefore asserts that “[r]emand is warranted for valuation and restitution of the
unrecovered … property.”
¶26 Jennifer raised this issue for the first time at the evidentiary hearing
on her motion, and the circuit court ordered that Jennifer would be permitted to
retrieve her property within 30 days. The court’s June 2025 order further stated
that contempt of court sanctions could apply if either party failed to comply with
the order. Jennifer does not dispute that she has not filed a motion for contempt
asserting that Delaine has failed to comply with the court’s order. Instead, she
contends, without citation to legal authority, that “a party is not required to
exhaust contempt remedies before appealing an order that provides internally
7
Jennifer also asserts that Delaine returned some items “broken.” As Delaine notes on
appeal, Jennifer did not allege in the circuit court that any of returned items were damaged.
Jennifer does not refute this assertion in her reply brief, and, accordingly, we deem this claim
forfeited. See Schill, 327 Wis. 2d 572, ¶45 n.21.
12
No. 2025AP1411
inconsistent or illusory relief.” Even if this legal assertion were true, Jennifer fails
to explain why the court’s property division decision is “inconsistent” or provides
“illusory” relief. See Pettit, 171 Wis. 2d at 646-47. The court’s ruling that
Jennifer would be required to file a motion for contempt if Delaine failed to
comply with the court’s order is supported by the fact that Jennifer did not raise
this issue until the evidentiary hearing, meaning Delaine would not have had
notice of such a claim prior to the hearing.
III. Maintenance
¶27 Finally, we address Jennifer’s argument that the circuit court erred
by denying her request to modify the maintenance award. “In order to modify a
maintenance award, the party seeking modification must demonstrate that there
has been a substantial change in circumstances warranting the proposed
modification.” Brin v. Brin, 2014 WI App 68, ¶7, 354 Wis. 2d 510, 849 N.W.2d
900 (citation omitted); see also WIS. STAT. § 767.59(1f). “A ‘substantial change’
in circumstances ‘must relate to a change in the financial circumstances of the
parties.’” Jahimiak v. Jahimiak, 2024 WI App 5, ¶42, 410 Wis. 2d 557, 2
N.W.3d 756 (2023) (citation omitted). “A circuit court’s decision as to whether
there has been a substantial change of circumstances is a discretionary one that
will be affirmed if there is a reasonable basis in the record to support it.” Id., ¶44.
¶28 Jennifer argues that the circuit court failed to account for her
“extraordinary medical expenses” when analyzing whether there had been a
substantial change in the parties’ financial circumstances since the court’s
October 2024 divorce judgment. According to Jennifer, she pays “over $17,000
annually … for treatment of a chronic bladder condition.”
13
No. 2025AP1411
¶29 Contrary to Jennifer’s argument, however, the circuit court
considered Jennifer’s new medical expenses in its analysis. In particular, the court
acknowledged that, according to Jennifer’s June 2025 financial disclosure
statement, Jennifer’s “medical and prescription expenses have increased from
$340 per month during the marriage to $800 per month following the divorce
(including medication and services related to a holistic acupuncturist which is not
typically considered a mainstream medical treatment).” Furthermore, the court
acknowledged that Jennifer had been diagnosed with melanoma since the final
divorce hearing, but it stated that there was no evidence in the record concerning
her prognosis. Significant to the court was the fact that Jennifer “continues to be
gainfully employed” and that her monthly income from her employment “actually
increased since the time of the final divorce hearing.” Meanwhile, Jennifer’s total
monthly expenses decreased by nearly $2,500, despite the increased medical and
prescription expenses.
¶30 Notably, Jennifer appears to actually be challenging the circuit
court’s basis for its original maintenance award in the October 2024 judgment.
This challenge is improper at this stage of the divorce proceedings. If Jennifer
wished to challenge the court’s October 2024 judgment, she was required to file a
direct appeal. “A ‘substantial change of circumstances’ determination calls for a
comparison of the facts on which the prior maintenance award was based to the
new facts in order to ascertain whether ‘the difference is enough to justify the
court’s considering whether to modify the order.’” Id., ¶42 (citation omitted). “A
court reviewing a modification request should adhere to the findings of fact made
in the previous proceeding setting maintenance and may not retry the factual
determinations decided in that proceeding.” Id. Accordingly, the court applied
the correct legal standard to Jennifer’s motion to modify maintenance by focusing
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No. 2025AP1411
on the parties’ changed financial circumstances since the time of the final divorce
hearing.8 On this record, we cannot say that the court erroneously exercised its
discretion.
¶31 In terms of the $17,000 figure cited by Jennifer, Jennifer did testify
as to this figure at the evidentiary hearing, stating that she has $17,000 in annual
out-of-pocket medical costs, evidence of which her attorney “neglected to bring
into court.” However, Jennifer’s June 2025 financial disclosure statement
represented that she had $800 per month ($9,600 annually) in medical expenses
not covered by insurance. Jennifer fails to explain or reconcile this discrepancy or
explain why the court unreasonably relied on her financial disclosure statement
when addressing the parties’ financial circumstances. See Pettit, 171 Wis. 2d at
646-47. Therefore, we do not consider further Jennifer’s argument that the circuit
court erred by failing to account for her $17,000 annual medical expenses when
concluding that a substantial change in her financial circumstances had not
occurred.9
By the Court.—Order affirmed.
This opinion will not be published. See WIS. STAT.
RULE 809.23(1)(b)5.
8
We further note that Jennifer does not challenge the circuit court’s conclusion that the
“vast number of medical records” she submitted in support of her motion to modify maintenance
did not constitute newly discovered evidence. Nor does she challenge the court’s conclusion that
none of the other provisions within WIS. STAT. § 806.07 warranted relief with respect to her
motion to change maintenance.
9
This court has made every effort to address each of Jennifer’s arguments on appeal.
However, to the extent that we have not addressed each of Jennifer’s arguments, we deem them
undeveloped and reject them on that basis. See Pettit, 171 Wis. 2d at 646-47.
15