It seems to me that maximum contact also means different things at different stages of a proceeding. For example, where mobility is the only issue, maximum contact is primarily relevant to the issue of contact with the access parent. However, mobility is not the only issue between the parties in this case. Custody remains an important and central issue. Generally, a decision regarding custody will precede a decision regarding mobility. The cases where a mobility decision may precede a custody decision will be limited for example, to those where there is no doubt that the parent seeking to move the child will be successful in the request for sole custody as was the case at para. 21 of Roberts v. Young, [2004] O.J. No. 1786, [2004] O.T.C. 409.
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