CANFIELD, JAMES P. v. MCCREE, LEE A.
Appellate Division of the Supreme Court of the State of New York
1Opinion of the Court
Memorandum:
Respondent mother appeals from an order granting petitioner father’s petition seeking to modify a prior order of custody and visitation entered upon the father’s default by awarding him increased visitation with the parties’ child. We affirm. The mother’s contention that Family Court improperly shifted the burden of proof by requiring her to establish that the father was not entitled to “standard” visitation is unpreserved for our review. The mother did not object to the court’s multiple statements concerning the burden of proof and, indeed, the mother’s attorney agreed with the…
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