The following excerpt is from Huffman v. Huffman, 403 N.Y.S.2d 850, 93 Misc.2d 790 (N.Y. City Ct. 1978):
A more precise balancing of the rights of the petitioner with the duties of the respondent is found in the decisions of foreign courts that have addressed the distinction. For instance, in Prager v. Smith, 195 A.2d 257 (1963), the District of Columbia Court of Appeals outlined the respective functions of the initiating and responding state courts:
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