Ness v. Martinez

Appellant raises several issues challenging the lower court's order denying her petition for relocation and granting Appellee's petition for modification of time-sharing. We address each of Appellant's arguments.

We reject Appellant's argument that the trial court violated the holding of Perlow v. Berg-Perlow , which states that while a proposed order "can serve as a starting point and reminder of the facts and issues that should be considered ... such submissions cannot substitute for a thoughtful and independent analysis ... by the trial judge." 875 So.2d 383, 389-90 (Fla. 2004). "But…