Exhibits

Every figure below is drawn by a script in model/charts/ from the models and data this site links elsewhere (The model, The data). None of these seventeen figures appears in the Comments prepared for the Trial Court (see Documents); they were built for the working paper and the correspondence that follows it. The number under each chart’s title states the arrangement, the number of children, whether child care is in the order, and the incomes used: the same fact pattern the chart itself states. One fact pattern does not generalize to every family; each figure’s notes say so again where it matters.

Contents

1. E01. Below about $230,000 of higher-earner income the recipient household usually holds more after the order; above it, the payor does.
2. E02. Per person, the payor holds more almost everywhere.
3. E03. The number of children decides which household holds more after the order.
4. E04. The order exceeds 40 percent of the payor’s net income only where the lower earner makes about $25,000 or less.
5. E05. The hardship valve fires late because it reads the wrong income.
6. E06. The payor’s share of a $15,600 child care bill, three ways to split it.
7. E07. Child care is split on an income distribution that base support has already changed.
8. E08. The Worksheet’s credit for equal parenting time collapses as the income gap widens; a cross-credit narrows without collapsing.
9. E09. At the worked example, equal parenting time is priced as a third of overnights at factor 1.5, and 47 percent at factor 2.0.
10. E10. Of the payor’s next dollar, the payor keeps between a third and a half.
11. E11. Equal parenting time: Massachusetts orders the most of fifty jurisdictions.
12. E12. Lower earner primary: only Hawaii’s Melson formula orders more than Massachusetts.
13. E13. A parent with the children a third of the time gets a formula credit in 28 jurisdictions and none in 23.
14. E14. Splitting the siblings cuts the order by a third while the schedule’s own cost measure rises 43 percent.
15. E15. When both parents pay child care, the payor bears 93 percent of it on 87 percent of the income.
16. E16. Massachusetts’s presumptive formula runs to $450,000; 12 schedules run higher, 28 stop lower.
17. E17. Massachusetts’s equal-time order exceeds the primary-custody order of 47 of the 49 other ranked jurisdictions.

Who holds more after the order

Below about $230,000 of higher-earner income the recipient household usually holds more after the order; above it, the payor does.

Recipient household net minus payor net, per year.

Custody

Joint, equal time (Box 1)

Children

3

Child care

None (base support)

Incomes

Vary (axes)

The recipient household is ahead in 55% of the grid, and in 96% of it below $150,000 of higher-earner income; nowhere above $230,000. The closed contour is Line 6e's limitation ceasing to bind once the payor's Line 6d crosses 10%, where the order drops about $110/wk in one step. Masked where the lower earner would out-earn the higher. Premiums $43/$33 a week; MA under-13 credit set to zero.

Source: model/charts/fig1_heatmaps.py; model/worksheet.py; model/net_position.py · data (CSV)

Per person, the payor holds more almost everywhere.

Recipient household net ÷ 4, minus payor net. Companion to E01.

Custody

Joint, equal time (Box 1)

Children

3

Child care

None (base support)

Incomes

Vary (axes)

The payor is ahead in 99% of the grid. This figure travels with E01 wherever E01 is shown, because the per-person comparison is the one a reader will raise first. Masked where the lower earner would out-earn the higher. Premiums $43/$33 a week; MA under-13 credit set to zero.

Source: model/charts/fig1_heatmaps.py; model/worksheet.py; model/net_position.py · data (CSV)

The number of children decides which household holds more after the order.

Recipient household net minus payor net. Red: recipient ahead; blue: payor ahead.

Custody

Joint, equal time (Box 1)

Children

1, 2 and 3

Child care

None (base support)

Incomes

Vary (axes)

With one child the payor is ahead across nearly the whole grid; with three the picture inverts below $230,000. The finding is about the child-count multiplier, Table B, not about any one family. Per person the payor leads throughout (E02). Colour capped at ±$40k. Masked where the lower earner would out-earn the higher. Premiums $43/$33 a week; MA under-13 credit set to zero.

Source: model/charts/fig1_heatmaps.py; model/worksheet.py; model/net_position.py · data (CSV): 1 child, 2 children, 3 children

The order exceeds 40 percent of the payor's net income only where the lower earner makes about $25,000 or less.

Order as a share of payor net; line at 40%.

Custody

Joint, equal time (Box 1)

Children

3

Child care

None (base support)

Incomes

Vary (axes)

The 40% contour, computed on net income, sits at a lower-earner income of about $25,000 up to roughly $235,000 of higher-earner income; above that, the order never reaches 40% of net at any lower-earner income on the grid (15% of cells). Scale fixed 0–60%. The region under the contour is the one Section IV.C's hardship presumption is written for; E05 shows what the Worksheet reports there. Masked where the lower earner would out-earn the higher. Premiums $43/$33 a week; MA under-13 credit set to zero.

Source: model/charts/fig1_heatmaps.py; model/worksheet.py; model/net_position.py · data (CSV)

The hardship test and its units

The hardship valve fires late because it reads the wrong income.

Line 7e's reading vs the true share of net income as claimed child care rises.

Custody

Joint, equal time (Box 1)

Children

3

Child care

Rises to the $430/child ceiling (recipient)

Incomes

$201,000 / $29,640

As child care claimed by the recipient rises, the true burden passes 40% of net at $80 a week of child care; Line 7e reports 40% at $590 a week, by which point the true burden is 57%. Nothing on the form flags the gap. Child care is included in the order. 7e is what the form computes; net is what is paid. Two of three children under 13 (MA credit); premiums $43/$33.

Source: model/charts/fig6_valve.py; model/submission_figures.py · data (CSV)

Of the payor's next dollar, the payor keeps between a third and a half.

Marginal retention after federal and state tax and the change in the order.

Custody

Joint, equal time (Box 1)

Children

3

Child care

None vs $300/wk (recipient)

Incomes

Varies / $29,640

The order's marginal take runs near 20 percent because the child-count multiplier and the rising income share both scale with the payor's income, so the effective rate exceeds Table A's 10 percent top bracket. $5,000 steps. Dashed: 50 cents. Two of three children under 13 (MA credit); premiums $43/$33.

Source: model/charts/fig4_retention.py; model/marginal_retention.py · data (CSV)

Child care

The payor's share of a $15,600 child care bill, three ways to split it.

Middle bar: the letter's § 2 redline (Line 6b-1).

Custody

Joint, equal time (Box 1)

Children

3

Child care

$300/wk, paid by the recipient

Incomes

$201,000 / $29,640

Line 3c allocates 87.7 percent to the payor on pre-transfer income shares. Adjusting the shares by the base order, the letter's § 2 redline, gives 64.5 percent. Post-transfer net shares give 48.2 percent. The middle bar is the redline; the right bar is where the argument goes once net income is admitted. Child care is included in the order. Two of three children under 13 (MA credit); premiums $43/$33.

Source: model/charts/fig2_childcare.py; model/childcare_post_transfer.py · data (CSV)

Child care is split on an income distribution that base support has already changed.

Share of the child care bill the payor funds under three rules, by income share.

Custody

Joint, equal time (Box 1)

Children

1, 2 and 3

Child care

$100/child/wk, paid by the lower earner

Incomes

$201,000 / varies

The same three rules across the income range for one, two and three children. The gap between the current rule and either alternative widens with the number of children and with the income gap. Dashed line: funded share equals income share. Child care is included in the order. Premiums $43/$33 a week; MA under-13 credit set to zero.

Source: model/charts/fig2_childcare.py; model/worksheet.py; model/net_position.py · data (CSV)

When both parents pay child care, the payor bears 93 percent of it on 87 percent of the income.

Who pays a combined $31,200 of child care, and each parent's net position.

Custody

Joint, equal time (Box 1)

Children

3

Child care

$300/wk in each home

Incomes

$201,000 / $29,640

Each parent pays $300 a week during their own parenting time, the ordinary case at equal time. The Worksheet allocates the recipient's cost to the payor through Line 6b and passes the payor's own cost back through Line 6e at about two cents on the dollar, so his own $15,600 reduces the order by $270 a year. Order plus his own child care reaches 58 percent of his net income while Line 7e reads 33 percent. Per person the payor still leads ($58,163 vs $22,907 each for four). Two of three under 13; premiums $43/$33.

Source: model/charts/fig8_both_pay.py; model/submission_figures.py · data (CSV)

Parenting time

The Worksheet's credit for equal parenting time collapses as the income gap widens; a cross-credit narrows without collapsing.

Reduction in the order for equal time vs the one-third-time (Box 2) order.

Custody

Joint (Box 1) vs primary (Box 2)

Children

3

Child care

None (base support)

Incomes

$201,000 / varies

The reduction falls from about 75 percent at a 57 percent payor income share to 7 percent at 88 percent and 1 percent at 96 percent, because no parenting-time quantity enters any line. Variant A, applying Line 6e once, lifts the curve; Variant B, the standard cross-credit at a 1.5 duplication factor used by 23 states, stops it collapsing. Variants A and B are the letter's § 5 redlines.

Source: model/charts/exhibits.py; model/worksheet.py; model/net_position.py; model/box1_fix.py · data (CSV)

At the worked example, equal parenting time is priced as a third of overnights at factor 1.5, and 47 percent at factor 2.0.

Overnight share that reproduces the Box 1 order under a cross-credit.

Custody

Joint (Box 1) vs primary (Box 2)

Children

3

Child care

None (base support)

Incomes

$201,000 / varies

The number depends on the duplication factor, so the factor is always stated beside it. The curve is blank below the Line 5c floor, where the order is no longer a cross-credit.

Source: model/charts/exhibits.py; model/worksheet.py; model/net_position.py; model/box1_fix.py · data (CSV)

Splitting the siblings cuts the order by a third while the schedule's own cost measure rises 43 percent.

Weekly order under Box 1 and Box 3 for the same two children, and Table B's cost of each.

Custody

Joint (Box 1) vs split (Box 3)

Children

2

Child care

None (base support)

Incomes

$201,000 / varies

Under Box 1 both are shared; under Box 3 one lives primarily with each parent. The payor's care responsibility is one child-share either way, but Line 6g nets the columns on the one-child schedule (Table B 1.00 against 1.40), so the Box 3 order comes out at 70 percent of the Box 1 order ($581 against $835 a week at the worked-example incomes), while two homes each carrying a first child cost 2.00 on Table B against 1.40 in one. This one cuts against the lower earner. Premiums $43/$33 a week; MA under-13 credit set to zero.

Source: model/charts/fig7_box3_split.py; model/worksheet.py; model/net_position.py · data (CSV): curve, worked-example point

Fifty-one jurisdictions

Equal parenting time: Massachusetts orders the most of fifty jurisdictions.

Monthly order at one fact pattern. Georgia held out.

Custody

Joint, equal time (Box 1)

Children

3

Child care

None (base support)

Incomes

$201,000 / $29,640

Fifty of fifty-one jurisdictions survived every verification stage; Georgia is held out because its enacted formula produces a lower order under primary custody than under equal time, which the state's own calculator reproduces. Each row profiled from primary sources, computed twice blind, reconciled, attacked. Own premiums ($43/$33) as each state treats them. One fact pattern; the ranking generalises to nothing else.

Source: model/charts/fig5_states.py · data (JSON) · data (CSV)

Full ranking behind E11 — all 50 jurisdictions

Monthly order, equal parenting time (S1) — full data behind E11

Rank	Jurisdiction	Monthly order
1	Massachusetts, this page’s worked example	$4,388.48
2	New York	$4,067.61
3	New Hampshire	$3,838.66
4	Texas	$3,510.00
5	Missouri	$3,139.00
6	Connecticut	$3,138.20
7	Wisconsin	$3,117.35
8	New Jersey	$3,002.31
9	North Dakota	$2,939.00
10	Maine	$2,899.02
11	Washington	$2,819.56
12	Hawaii	$2,774.00
13	Rhode Island	$2,684.45
14	Colorado	$2,652.32
15	Iowa	$2,630.25
16	Ohio	$2,564.15
17	California	$2,424.32
18	Pennsylvania	$2,378.42
19	Alaska	$2,367.95
20	Maryland	$2,309.54
21	Kansas	$2,296.63
22	Indiana	$2,283.25
23	Delaware	$2,281.35
24	District of Columbia	$2,253.73
25	Louisiana	$2,227.23
26	Arkansas	$2,118.68
27	Mississippi	$2,097.44
28	Wyoming	$1,900.85
29	North Carolina	$1,883.12
30	Illinois	$1,881.45
31	Virginia	$1,872.18
32	Nevada	$1,842.80
33	Tennessee	$1,833.00
34	South Carolina	$1,832.22
35	New Mexico	$1,823.64
36	Idaho	$1,794.22
37	South Dakota	$1,788.96
38	Alabama	$1,746.00
39	Florida	$1,735.21
40	West Virginia	$1,724.21
41	Vermont	$1,686.42
42	Nebraska	$1,475.23
43	Montana	$1,461.00
44	Michigan	$1,445.25
45	Arizona	$1,309.36
46	Oklahoma	$1,284.42
47	Minnesota	$1,174.71
48	Kentucky	$1,087.80
49	Oregon	$1,072.00
50	Utah	$1,058.31

Lower earner primary: only Hawaii's Melson formula orders more than Massachusetts.

Monthly order at one fact pattern. Georgia held out.

Custody

Primary with the lower earner (Box 2)

Children

3

Child care

None (base support)

Incomes

$201,000 / $29,640

The same fact pattern with the children primarily with the lower earner. Hawaii's design is shared with Delaware and Montana; at this income gap it exhausts the self-support reserve differently from an income-shares schedule. Each row profiled from primary sources, computed twice blind, reconciled, attacked.

Source: model/charts/fig5_states.py · data (JSON) · data (CSV)

Full ranking behind E12 — all 50 jurisdictions

Monthly order, children primarily with the lower earner (S2) — full data behind E12

Rank	Jurisdiction	Monthly order
1	Hawaii	$5,821.00
2	Massachusetts, this page’s worked example	$4,714.22
3	Wisconsin	$4,491.71
4	New York	$4,067.61
5	Delaware	$3,990.73
6	New Hampshire	$3,838.66
7	Kansas	$3,838.03
8	Iowa	$3,744.73
9	Texas	$3,510.00
10	District of Columbia	$3,467.96
11	Alaska	$3,462.96
12	California	$3,436.04
13	Maryland	$3,295.11
14	Louisiana	$3,269.06
15	North Dakota	$3,219.00
16	Missouri	$3,139.00
17	Connecticut	$3,138.20
18	Rhode Island	$3,123.22
19	Colorado	$3,090.30
20	Pennsylvania	$3,086.76
21	Montana	$3,073.50
22	Illinois	$3,037.90
23	New Jersey	$3,002.31
24	North Carolina	$2,934.30
25	Maine	$2,899.02
26	Washington	$2,819.56
27	Michigan	$2,808.44
28	Wyoming	$2,801.97
29	New Mexico	$2,795.32
30	Alabama	$2,736.00
31	Virginia	$2,672.09
32	South Carolina	$2,669.21
33	South Dakota	$2,623.12
34	Vermont	$2,594.42
35	Mississippi	$2,564.76
36	Ohio	$2,564.15
37	Idaho	$2,549.85
38	Indiana	$2,548.03
39	West Virginia	$2,518.77
40	Florida	$2,512.99
41	Nevada	$2,485.00
42	Nebraska	$2,402.03
43	Arkansas	$2,349.64
44	Utah	$2,332.66
45	Arizona	$2,290.06
46	Minnesota	$2,271.30
47	Tennessee	$2,031.00
48	Oklahoma	$2,008.78
49	Kentucky	$1,871.67
50	Oregon	$1,772.00

A parent with the children a third of the time gets a formula credit in 28 jurisdictions and none in 23.

Blue: a formula credit at 122 overnights a year. Grey: none.

Counted

Any formula credit at 122 overnights

Children

3

Child care

None

Incomes

$201,000 / $29,640

A count, not a dollar amount. Massachusetts is among the 23; its Box 2 is the one-third case. In the one clean pairing with a credit-giving state the dollar effect runs the other way, so the count is a structural fact and nothing more.

Source: model/charts/fig5_states.py · data (JSON)

Full table behind E13 — all 51 jurisdictions

Formula credit at 122 overnights (one-third time), by jurisdiction — full data behind E13

Jurisdiction	Formula credit at 122 overnights
Alabama	No
Alaska	Yes
Arizona	Yes
Arkansas	No
California	Yes
Colorado	Yes
Connecticut	No
Delaware	Yes
District of Columbia	No
Florida	Yes
Georgia	Yes
Hawaii	No
Idaho	Yes
Illinois	No
Indiana	Yes
Iowa	No
Kansas	No
Kentucky	Yes
Louisiana	No
Maine	No
Maryland	Yes
Massachusetts, this page’s worked example	No
Michigan	Yes
Minnesota	Yes
Mississippi	No
Missouri	Yes
Montana	Yes
Nebraska	No
Nevada	No
New Hampshire	No
New Jersey	Yes
New Mexico	No
New York	No
North Carolina	No
North Dakota	Yes
Ohio	Yes
Oklahoma	Yes
Oregon	Yes
Pennsylvania	No
Rhode Island	No
South Carolina	Yes
South Dakota	Yes
Tennessee	Yes
Texas	No
Utah	Yes
Vermont	Yes
Virginia	Yes
Washington	No
West Virginia	No
Wisconsin	Yes
Wyoming	Yes

Massachusetts's presumptive formula runs to $450,000; 12 schedules run higher, 28 stop lower.

Combined income at which each state's presumptive schedule ends; above it, support is discretionary.

Ranked

41 combined-income schedules (29 gross, 11 net, 1 other basis)

Not ranked

10: percentage-of-obligor, Melson or open formula

Basis

Annual; monthly ×12, weekly ×52

Forty-one jurisdictions have a combined-income schedule that stops at a stated figure; the median is $360,000, seven stop at exactly $40,000 a month, and Utah's runs to $1.2 million. Ten jurisdictions use a percentage-of-obligor, Melson or open formula with no combined ceiling. Net-income ceilings are not dollar-for-dollar comparable with gross ones. Not ranked: Alaska, California, Delaware, Hawaii, Mississippi, Montana, Nevada, North Dakota, Texas, Wisconsin. This figure corrects an earlier comparison against nine benchmark states, in which Massachusetts appeared second; of the 41 jurisdictions with a stated combined-income ceiling it is thirteenth.

Source: model/charts/fig9_ceilings.py · data (JSON) · data (CSV)

Full ranking behind E16 — 41 combined-income schedules

Combined income at which the presumptive schedule stops — full data behind E16

Rank	Jurisdiction	Combined-income ceiling	Basis
1	Utah	$1,200,000	gross
2	Louisiana	$600,000	gross
3	Washington	$600,000	net
4	Virginia	$510,000	gross
5	Colorado	$480,000	gross
6	Georgia	$480,000	gross
7	Missouri	$480,000	gross
8	New Mexico	$480,000	gross
9	North Carolina	$480,000	gross
10	Rhode Island	$480,000	gross
11	South Carolina	$480,000	gross
12	Indiana	$478,400	gross
13	Massachusetts, this page’s worked example	$450,000	gross
14	Idaho	$440,000	gross
15	West Virginia	$420,000	gross
16	Maine	$400,000	gross
17	New Hampshire	$373,068	gross
18	Vermont	$360,300	other
19	Alabama	$360,000	gross
20	Arizona	$360,000	gross
21	Arkansas	$360,000	gross
22	Iowa	$360,000	net
23	Kentucky	$360,000	gross
24	Maryland	$360,000	gross
25	Oregon	$360,000	gross
26	Pennsylvania	$360,000	net
27	South Dakota	$360,000	net
28	Tennessee	$339,000	gross
29	Ohio	$336,000	gross
30	Illinois	$328,500	net
31	Connecticut	$312,000	net
32	District of Columbia	$240,000	gross
33	Minnesota	$240,000	gross
34	Nebraska	$240,000	net
35	Kansas	$216,000	gross
36	Michigan	$214,459	net
37	New York	$193,000	gross
38	New Jersey	$187,200	net
39	Oklahoma	$180,000	gross
40	Wyoming	$180,000	net
41	Florida	$120,000	net

Massachusetts's equal-time order exceeds the primary-custody order of 47 of the 49 other ranked jurisdictions.

Monthly order: Massachusetts under Box 1 (children half the time each) against every other jurisdiction with the children primarily with the lower earner.

Custody

MA equal time (Box 1) vs others primary

Children

3

Child care

None (base support)

Incomes

$201,000 / $29,640

Only Hawaii and Wisconsin order more at primary custody than Massachusetts does at equal time; Massachusetts's own primary-custody order, $4,714, is marked for scale and is not part of the ranked comparison. The Commonwealth's consultant attributes the higher amounts to the cost of living, which bears on both households in the order; whatever it explains about the level, it does not explain why an arrangement that gives each parent half the children's time is priced here where sole primary custody is priced almost everywhere else. One fact pattern. Georgia held out. Each row profiled from primary sources, computed twice blind, reconciled, attacked. Own premiums $43/$33 as each state treats them.

Source: model/charts/fig10_ma_shared_vs_primary.py · data (JSON) · data (CSV)

Full ranking behind E17 — Massachusetts vs. 49 other jurisdictions' primary-custody orders

Massachusetts’s equal-time order vs. every other jurisdiction’s primary-custody order — full data behind E17

Rank	Jurisdiction	Custody basis	Monthly order
1	Hawaii	Primary, lower earner	$5,821.00
—	Massachusetts, this page’s worked example	Primary (Box 2) — for scale, not ranked	$4,714.22
2	Wisconsin	Primary, lower earner	$4,491.71
3	Massachusetts, this page’s worked example	Equal time (Box 1)	$4,388.48
4	New York	Primary, lower earner	$4,067.61
5	Delaware	Primary, lower earner	$3,990.73
6	New Hampshire	Primary, lower earner	$3,838.66
7	Kansas	Primary, lower earner	$3,838.03
8	Iowa	Primary, lower earner	$3,744.73
9	Texas	Primary, lower earner	$3,510.00
10	District of Columbia	Primary, lower earner	$3,467.96
11	Alaska	Primary, lower earner	$3,462.96
12	California	Primary, lower earner	$3,436.04
13	Maryland	Primary, lower earner	$3,295.11
14	Louisiana	Primary, lower earner	$3,269.06
15	North Dakota	Primary, lower earner	$3,219.00
16	Missouri	Primary, lower earner	$3,139.00
17	Connecticut	Primary, lower earner	$3,138.20
18	Rhode Island	Primary, lower earner	$3,123.22
19	Colorado	Primary, lower earner	$3,090.30
20	Pennsylvania	Primary, lower earner	$3,086.76
21	Montana	Primary, lower earner	$3,073.50
22	Illinois	Primary, lower earner	$3,037.90
23	New Jersey	Primary, lower earner	$3,002.31
24	North Carolina	Primary, lower earner	$2,934.30
25	Maine	Primary, lower earner	$2,899.02
26	Washington	Primary, lower earner	$2,819.56
27	Michigan	Primary, lower earner	$2,808.44
28	Wyoming	Primary, lower earner	$2,801.97
29	New Mexico	Primary, lower earner	$2,795.32
30	Alabama	Primary, lower earner	$2,736.00
31	Virginia	Primary, lower earner	$2,672.09
32	South Carolina	Primary, lower earner	$2,669.21
33	South Dakota	Primary, lower earner	$2,623.12
34	Vermont	Primary, lower earner	$2,594.42
35	Mississippi	Primary, lower earner	$2,564.76
36	Ohio	Primary, lower earner	$2,564.15
37	Idaho	Primary, lower earner	$2,549.85
38	Indiana	Primary, lower earner	$2,548.03
39	West Virginia	Primary, lower earner	$2,518.77
40	Florida	Primary, lower earner	$2,512.99
41	Nevada	Primary, lower earner	$2,485.00
42	Nebraska	Primary, lower earner	$2,402.03
43	Arkansas	Primary, lower earner	$2,349.64
44	Utah	Primary, lower earner	$2,332.66
45	Arizona	Primary, lower earner	$2,290.06
46	Minnesota	Primary, lower earner	$2,271.30
47	Tennessee	Primary, lower earner	$2,031.00
48	Oklahoma	Primary, lower earner	$2,008.78
49	Kentucky	Primary, lower earner	$1,871.67
50	Oregon	Primary, lower earner	$1,772.00

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