Habecker v. Giard

¶ 1. Mother appeals from a Chittenden Family Court order granting legal and physical custody of the parties’ four children to father. Mother, who is not married to father, claims that the court erred by: 1) finding a real, substantial and unanticipated change of circumstances when the evidence did not support such a finding; 2) concluding that transfer of physical custody and legal parental rights and responsibilities to father was in the children’s best interests; and 3) improperly placing the bur den upon mother to file a motion to modify custody order prior to relocating. We affirm.

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