The only previous order in this proceeding is an interim order. Interim orders are subject to change without proof of a “change in circumstances”. Orders, other than interim orders, do require this threshold finding before any changes can be made to the content of the order. In the often quoted “mobility case” Gordon v. Goertz, 1996 CanLII 191 (SCC), [1996] 2 S.C.R. 27 there was a prior order that was not an interim order. Nevertheless the analysis provided in Gordon v. Goertz , supra, has been considered useful in cases where there is an interim order and also in cases where there is no order governing the relationship between parents and children. FACTORS TO CONSIDER IN A MOBILITY CASE
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