Ordered that the order is affirmed, with costs.
The plaintiff's application, inter alia, for a judgment for arrears and a contempt adjudication, pursuant to Domestic Relations Law §§ 244 and 245, respectively, was properly denied. The foreign divorce decree at issue neither incorporates the parties' separation agreement by reference nor specifically directs payment by the defendant of any stated sum (Baker v Baker, 66 N.Y.2d 649; Sileo v Sileo, 115 A.D.2d 535). Further, neither law of the case nor any theory of equitable estoppel based upon the defendant's earlier efforts to reduce his support obligation compels a different result. There is no court order or judgment which directs the defendant to pay the sums now sought by the plaintiff (cf., Baratta v Baratta, 122 A.D.2d 3). The monetary relief which the plaintiff seeks must, therefore, be pursued by a plenary action on the agreement. Mollen, P.J., Brown, Kunzeman and Kooper, JJ., concur.