Impossible to answer. Missing information is what is your ex's income.
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Too many unanswered questions to give you any direction but if he can make a case that there are changed circumstances (I can think of a hundred ways to do that), then he may get the modification he seeks.
The best advice anyone could give you is: hire a family law attorney to help you. It is an unfair fight--he is a lawyer and you don't have counsel. Under the right facts, you should be able to get attorney's fees.
I don't know why you would file an OSC for arrears? If there is a court order for support and arrears accumulated because of lack of payment, then you don't need another court order. If you are entitled to $3500 in support, then you should be able to find an attorney to assist you. Good luck.
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