In S.S.L. v. J.W.W., 2010 BCCA 55, Madam Justice Huddart observed (at para. 22), that the factors listed at paragraph 49 of Gordon v. Goertz . . . provide insufficient guidance for two good parents, their counsel, and the trial court as they face the agonizing decision required in two circumstances: (1) a pre-school age child who has been in the primary care of one parent (usually the mother) where age-appropriate access is unworkable if one parent moves away . . . and (2) a joint parenting situation where one or both parents’ needs (economic, educational or personal) are seen as requiring a change.
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