[18] As noted by Blishon J. in Jennings v. Garrett, supra at paragraphs 135 - 140, the factors most commonly considered by the courts in terminating access and often equally applicable when deciding whether to order supervised access are the following: 1. Long term harassment and harmful behaviours towards the custodial parent causing that parent and the child stress and or fear. 2. History of violence; unpredictable, uncontrollable behaviour; alcohol, drug abuse which has been witnessed by the child and/or presents a risk to the child's safety and wellbeing. 3. Extreme parental alienation which has resulted in changes of custody and, at times, no access orders to the former custodial parent. 4. Ongoing severe denigration of the other parent. 5. Lack of relationship or attachment between noncustodial parent and child. 6. Neglect or abuse to a child on the access visits. 7. Older children's wishes and preferences to terminate access.
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