The following excerpt is from M. v. L.M., 2019 NY Slip Op 50963 (U) (N.Y. Fam. Ct. 2019):
A parent's willingness to foster a positive relationship between the child and the noncustodial parent is integral to the determination of his or her relative fitness as a parent. (See Matter of Jarvis v. Lashley, 169 AD3d 1043, 1044 [2d Dept. 2019]). A custodial parent must "place the needs of the child[] before her own in fostering a continued relationship with the
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noncustodial parent". (Young v. Young, 212 AD2d 114, 123 [2d Dept. 1995]).
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