In Children’s Aid Society of Brant v. A.H., 2020 ONCJ 49, Hilliard J. agreed with Sager J.’s approach on the threshold issue of change. However, she added a further nuance that a different amount of change may be appropriate when the request is to change a placement, versus a request to change parenting time. Hilliard J. referred to the test to change parenting time as being even “significantly lower”.
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