The importance of overnight visits was commented upon by Spence J. in Heuss v. Surkos, 2004 CarswellOnt 3517 (O.C.J.), at para. 30, as follows: First, it is important to maximize the contact between access parents and young children. Second, it is important that this contact be meaningful such that the relationship between them is allowed to flourish. Third, unless specific circumstances exist which point in a different direction, that contact should include regular overnight visits. And fourth, the overnights should be of sufficient duration and frequency to permit the relationship to flourish. [Emphasis added]
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