The requisite steps need not be dramatic. For example, Cooperman v. Cooperman, 2008 ONCJ 119 (C.J.) was a case in which a father was precluded by court order from letting his child associate with his new girlfriend who was already in the picture, so to speak. He subsequently moved in with her - which arguably was foreseeable when the prohibition was imposed and therefore was not a material change that warranted variation when it occurred. But, the prohibition was deleted upon his variation request.
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