The following excerpt is from Marks v. Hochhauser, 876 F.3d 416 (2nd Cir. 2017):
Notwithstanding this ambiguity, there are a number of considerations that demonstrate that "retention" is a singular act for the purpose of the Convention"wrongful retention" occurs when one parent, having taken the child to a different Contracting State with permission of the other parent, fails to return the child to the first Contracting State when required. See generally Taveras v. Morales , 22 F.Supp.3d 219, 231-32 (S.D.N.Y. 2014).
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