California, United States of America
The following excerpt is from Begier v. Strom, 46 Cal.App.4th 877, 54 Cal.Rptr.2d 158 (Cal. App. 1996):
Then in Chauncey v. Niems (1986) 182 Cal.App.3d 967, 227 Cal.Rptr. 718, the court held that the husband had failed to show that the wife's order to show cause (OSC) re contempt and OSC re modification of child visitation and support were terminated in his favor. The court reasoned that because the parties' child visitation dispute was settled by mutual agreement it was not possible to infer guilt or innocence, favorability or unfavorability. (Id. at pp. 976-977, 227 Cal.Rptr. 718.) 9
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