California, United States of America
The following excerpt is from Polakoff v. Polakoff, B266928 (Cal. App. 2017):
"'The standard of appellate review of custody and visitation orders is the deferential abuse of discretion test.'" (Montenegro v. Diaz (2001) 26 Cal.4th 249, 255 (Montenegro), quoting In re Marriage of Burgess (1996) 13 Cal.4th 25, 32
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