She observed that the PhD would ultimately result in an improvement of circumstances for the child. She distinguishes Burgin v. Howells, 2004 NSSC 31, where a parent was given permission to take the child to England. She went on to observe that the case returned to court to deal with access issues and problems flowing from an unworkable plan. She emphasized the principle that ensuring maximum contact between the parents is a goal of a custody and access order.
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