In this case, the application for a review of parenting time was heard with the mother’s application to relocate. It is common ground that on this review of parenting time, the father need not establish a threshold finding of a material change of circumstances. Instead, as with a review of an earlier order for spousal support, the review is a hearing de novo and treated as an initial application: Morck v. Morck, 2013 BCCA 186 at paras. 16 and 17.
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