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Cases of Interest: Modifications
National Legal Research Group, Inc.

CONNECTICUT: Fiddelman v. Redmon, 37 Conn. App. 397, ___ A.2d ___ (1995).
"Birdnesting" arrangements have become increasingly popular. Under this arrangement, the divorced parents take turns living in the former marital home with the children; when the parent is not with the children, he or she lives elsewhere.
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IOWA: In re Crew, 22 Fam. L. Rep. (BNA) 1432 (Iowa 1996).
After the parties were divorced in California, the mother and children moved to Iowa, and the father moved to the State of Washington. Over the next few years, the father called the children in Iowa and made arrangements for them to visit him in Washington.
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OHIO: Sayre v. Hoelze-Sayre, 100 Ohio App. 3d 203, 653 N.E.2d 712 (1994).
The father moved for modification of the child custody decree. Specifically, the father alleged that the mother had refused to enroll the children in an accredited school, and had instead insisted on home schooling. The home schooling resulted in deficient skills exhibited by the children.
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WYOMING: Ready v. Ready, 906 P.2d 382, 384 (Wyo. 1995).
The parties were divorced in 1990, and the mother was awarded custody of the parties' four children. The father was awarded visitation, but over the following years his visitation was persistently frustrated by the mother.
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