What is husband's burden to demonstrate to the court that there has been no change in circumstance or increased risk of abduction?

California, United States of America


The following excerpt is from Fitzgerald v. Fitzgerald (In re Patrick), C085843 (Cal. App. 2018):

We reiterate that it was husband's burden to demonstrate a change in circumstance sufficient to support modification of the final child custody and visitation order. (Montenegro v. Diaz, supra, 26 Cal.4th at p. 256.) On appeal, husband has identified no such facts indicating a change in circumstance or how the court abused its discretion in finding no increased risk of abduction since the judgment. While husband attempts to convince us that his experts were more knowledgeable and qualified on the issue and the

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