Griffin & Laidley
[2021] FCCA 1515
•20 July 2021
FEDERAL CIRCUIT COURT OF AUSTRALIA
Griffin & Laidley [2021] FCCA 1515
File number(s): LEC 556 of 2020 Judgment of: JUDGE L. TURNER Date of judgment: 20 July 2021 Catchwords: FAMILY LAW – Parenting – where applicant was sperm donor – where respondent argues applicant is not a parent – Held facts and circumstances support applicant is a parent Legislation: Family Law Act 1975 (Cth) ss 65C, 60G, 60H, 69ZL, Pt VII Cases cited: Masson v Parsons [2019] HCA 21 Number of paragraphs: 42 Date of last submission/s: 1 June 2021 Date of hearing: 21 April 2021 Place: Brisbane Solicitor for the Applicant: Mr Beneke of Coffs Law Co Solicitor for the Respondent: Mr Craig of Pollack Greening And Hampshire ORDERS
LEC 556 of 2020 BETWEEN: MR GRIFFIN
Applicant
AND: MS LAIDLEY
Respondent
ORDER MADE BY:
JUDGE L. TURNER
DATE OF ORDER:
20 JULY 2021
THE COURT ORDERS BY WAY OF PARENTING ORDER THAT:
1.The applicant is the parent of X born in 2020 (the child).
2.Within 21 days from the date hereof the respondent file and serve an amended response setting out the parenting orders sought by the respondent on an interim and final basis.
3.Within 14 days from the date hereof the parties complete intake for the applicant to spend supervised time with the child with B Contact Centre.
4.That the parties shall attend a Child Dispute Conference with Family Consultant Ms C or such other Family Consultant as nominated by the Senior Family Consultant of the Federal Circuit Court of Australia, Brisbane at 9:00am on 15 September 2021 at the Family Law Courts, Level 2, 29-31 Molesworth Street, Lismore.
5.That pursuant to s.11F of the Family Law Act 1975, the Family Consultant shall provide an advice to the Court and the parties that may include:
(a)identification of the issues for the child;
(b)a consideration of the relevant factors contained in s.60CC of the Act and an appropriate parenting plan for the child until there can be further investigations into the matter; and
(c)such programmes as may assist the parties establish a better functioning co-parenting relationship and more positive and effective communication or that might assist them in the development of their parenting skills.
6.That the Family Consultant shall have leave to inspect any subpoenaed documents.
7.That the Family Consultant provide a written memo to the Court.
8.That this matter be adjourned for Mention by telephone at 11:30am on 3 November 2021 in the Federal Circuit Court of Australia at Brisbane.
Section 121 of the Family Law Act 1975 (Cth) makes it an offence, except in very limited circumstances, to publish proceedings that identify persons, associated persons, or witnesses involved in family law proceedings.
IT IS NOTED that publication of this judgment under the pseudonym Griffin & Laidley is approved pursuant to s.121(9)(g) of the Family Law Act 1975 (Cth).
REASONS FOR JUDGMENT
JUDGE L. TURNER:
INTRODUCTION
The applicant is the biological father (applicant) and the respondent is the biological mother (respondent) of the child X aged 1.
The parties are in dispute as to whether the applicant is a parent and therefore able to seek parenting orders in respect to the child.
PROPOSALS
Applicant
The applicant seeks a finding that he is a parent to the child and therefore is able to pursue his application to spend time with the child.
Respondent
The respondent seeks orders that the application for parenting orders filed by the applicant be dismissed on the basis that the applicant is not a parent of the child.
ISSUE
The issue for determination is whether the applicant is a parent and therefore is able to pursue parenting orders.
EVIDENCE
In considering this issue regard has been had to:
(a)The relevant material on the digital court file.
(b)The written submissions of the parties.
(c)Part VII Family Law Act 1975.
(d)The relevant authorities.
The parties are legally represented.
Cross-examination did not occur.
The submissions of the parties have been properly considered in reaching a determination although each submission may not have been specifically addressed or responded to in the judgment (Baghti & Baghti [2015] Fam CAFC 71).
Findings of fact are made on the balance of probabilities having regard to the evidence and in what follows statements of fact constitute findings of fact.
Pursuant to section 69ZL(1) Family Law Act1975 the reasons for judgment have been delivered in short form.
RELEVANT FACTS
The relevant facts are as follows:
(a)The applicant is aged 28.
(b)The respondent is aged 28.
(c)In 2018 the parties met and became friends.
(d)In 2019 the respondent attended upon an appointment with her gynaecologist about having a child who suggested that the respondent ask a gay friend to be a sperm donor as one of the options for pregnancy.
(e)In 2019 the respondent informed the applicant that she was considering undertaking IVF in order to have a child.
(f)In 2019 the parties agreed to be a sperm donor. Subsequently the respondent purchased an insemination kit online.
(g)In 2019 the applicant provided the respondent with semen in a specimen jar and the respondent inseminated herself.
(h)In 2019 the respondent found out that she was pregnant.
(i)In 2019 the respondent attended two ultrasounds.
(j)In 2019 the respondent informed the applicant that she was pregnant.
(k)The parties continued in their friendship and informed others as to the pregnancy and the applicant having donated his sperm.
(l)In 2019 the parties attended the 12 week ultrasound.
(m)In 2020 the parties attended the 20 week ultrasound where the parties were informed that the respondent was having a boy.
(n)In 2020 the parties exchanged text messages as to possible names for the child where the parties agreed to the name “X” with the respondent confirming in a text message sent in 2020 “Ahha…we got the 1st name settled :)… I did wanna put something from your name in his though:)”
(o)In 2020 the respondent attended her first midwife appointment.
(p)In 2020 the respondent attended parenting classes alone.
(q)In 2020 a document was prepared headed “Baby Agreement” dated 2020 which contained the following:
(i)“*How much involvement do you want? (Weekdays, weekends, monthly?) (Just visit or ….(word crossed out))”
(ii)“Visits and every now and then babysit the baby”
(r)In 2020 the applicant spoke to the respondent about wanting equal time with the child and provided to the respondent a written proposal that read:
This is a legal document between the parents of X. The mother being Ms Laidley and the father being Mr Griffin. When Mr Griffin has visitation rights during breastfeeding stage Ms Laidley must leave the premises for one day and one night, so it allows for Mr Griffin to have X in his routine. During the first 6 weeks period of X’s life Mr Griffin is to have at least two days a week of visitation of X. If X needs a doctor’s appointment or hospitalisation the other parent must be notified. 50-50 in the upbringing of X. Legally the last name must remain the same. After X is 6 weeks old visitation for both parents be one week on a one week off (unless X is breastfed then it goes to 4 days each)
(s)In 2020 the respondent messaged the applicant in a text dated 2020 which read:
I am not agreeing to this. We never discussed any of this in our talk on visiting X. You completely changed everything I suggested on visiting X. I’ve seen someone for advice. And we can start mediation after X is born and settled. You are putting stress on me right now and it’s not good for X either. Please stop
(t)In 2020 the applicant sent a series of unanswered text messages and made numerous calls with the applicant writing in a text message dated 2020 “I’m trying to get the X stuff organised nicely so we don’t have to go to court but if I don’t hear from you this week I’ll go get a lawyer” to which the respondent replied “I don’t wish to discuss this any further. You will be getting contacted by my solicitor”.
(u)Thereafter the friendship ceased.
(v)In 2020 the child X was born with the respondent not informing the applicant as to the child’s birth although the applicant had telephoned the respondent multiple times.
(w)In 2020 when the applicant found out that the respondent was in hospital having the baby he attended the hospital. The respondent refused to allow the applicant to hold the baby and told the applicant to leave, which he did.
(x)In 2020 the respondent lodged a complaint with the New South Wales Government as to how the staff at the City D Hospital dealt with the applicant’s attendance at the hospital.
(y)In 2020 the respondent moved without informing the applicant as to her new address.
(z)In July 2020 the applicant attempted to organise a family dispute resolution conference and a letter was sent to the respondent.
(aa)In August 2020 the Region E NSW Local Health District wrote to the respondent advising that the applicant was allowed access to the respondent after stating that he was the respondent’s partner.
(bb)In August 2020 a Section 60I certificate was issued after the conference organiser considered that it was not a matter where it was not appropriate to conduct a family dispute resolution.
(cc)In August 2020 the applicant filed parenting proceedings seeking final orders whereby the parties have equal shared parental responsibility for the child and the child live week about with each party and interim orders for a location order, for the parties to attend family dispute resolution, for the parties to have equal shared parental responsibility for the child, for the child to live with the respondent and for the child to spend supervised time with the applicant at B Contact Centre.
(dd)In the accompanying Notice of Risk the applicant raised no concerns as the child being at risk in the care of the respondent.
(ee)In November 2020 a location order was made for the respondent.
(ff)In January 2021 the respondent was served with the applicant’s application and supporting documents.
(gg)In April 2021 the respondent filed her response seeking final and interim orders whereby the applicant’s application be dismissed and the respondent have sole parental responsibility for the child.
(hh)In the accompanying Notice of Risk the respondent raised no concerns as to the child being at risk in the applicant’s care.
(ii)In April 2021the matter proceeded to a hearing with directions made for the filing of submissions.
As at the date of the hearing:
(a)The child is living with the respondent.
(b)The applicant has not spent any time with the child.
Before considering the law it is useful to capture what each party has to say.
WHAT THE APPLICANT SAYS
The applicant submits in his written submissions that:
(a)The applicant quotes the High Court decision of Masson v Parsons [2019] HCA 21 in support of his application [7] to [9].
(b)In turning to the facts of this matter the parties intended the biological father to be involved in the care and raising of the child and on this basis the applicant should be legally recognised as a parent [10].
(c)People knew that the applicant was the biological father of the child [16].
(d)The applicant being in attendance when the respondent was congratulated on being pregnant demonstrated an investment on his part of supporting the respondent through her pregnancy [17].
(e)The parties discussed the name for the child [19].
(f)The respondent acknowledged that the parties had selected the first name of the child and that the respondent wanted to include something from the applicant’s name in the name of the child [21].
(g)This suggests a level of co-parenting as there was a joint decision as to the naming of the child and therefore the applicant was more than just a sperm donor [23].
(h)The respondent had sent a message to the applicant suggesting that a big Christmas party for the child which reinforces the involvement of the applicant beyond that of a sperm donor [24].
(i)The parties had discussed that the applicant have visits with the child as well as babysit the child [25].
(j)This is evidence that both parties expected and had agreed for the applicant to spend time with the child and by virtue of this interact, with the child as a parent [26].
(k)The involvement between the parties and the intended involvement of the applicant’s inherently above and beyond that just a sperm donor [27].
(l)The applicant states that he provided the semen sample on the condition that he would be involved in the child’s life [29].
(m)The applicant states that they had discussions about parenting topics including naming the child, co-parenting and taking holidays together [31].
(n)The applicant attended ultrasounds with the respondent [34].
(o)The parties have had discussions about the level of involvement of the applicant with the child before the child’s birth [35].
(p)The applicant indicated that he wanted week about with the child which demonstrated that his commitment with the child was greater than that of a sperm donor [39].
(q)The dispute as to the amount of time the applicant would have with the child is what caused the breakdown in the friendship between the parties [40] and [41].
(r)The applicant has been denied an opportunity to be involved in the parenting of the child since the birth of the child by the unilateral decisions of the respondent [42] and [43].
(s)If there had not been a dispute about the level of contact the applicant was to spend with the child, then it was likely that the applicant would have been involved in the care and support of the child [44].
(t)The facts in this matter are different to the facts in Masson v Parsons because the applicant not being involved in the parenting of the child post the birth is no fault of his own [45].
(u)The determination therefore must be based on the pre-birth actions and the intentions of the parties [47].
(v)The respondent’s position that the applicant is purely a sperm donor and that his only involvement would be as a friend to the child is contradicted by the respondent’s own evidence which details a general knowledge of who the biological father was, the applicant attending medical appointments, the applicant assisting in the naming of the child, the respondent stating that she wished for the child to have part of the applicant’s name and the parties entering into agreements and negotiations as to the amount of time the applicant was to spend with the child [28] and [49].
(w)This evidence does not describe that of a sperm donor and describes a level of involvement which is more in to that of a parent [50].
WHAT THE RESPONDENT SAYS
The respondent submits in her written submissions that:
(a)The child was born as a result of an informal donation of sperm by the applicant to the respondent [28].
(b)Masson v Parsons dealt with the issue of whether state law provides an irrebuttable presumption that a biological child conceived by a fertilisation procedure is not the father of the child. It was ultimately held that section 60H and section 60G Family Law Act 1975 are not exhaustive and therefore the state legislation presumption does not apply [29].
(c)The case provides that the term “parent” should be taken to have ordinarily, accepted English meaning [30].
(d)Section 60H does not deal with the situation to be determined in this case [31].
(e)The question of whether a mere sperm donor, who does no more than provide his semen is a parent is not determined by Masson v Parson [32].
(f)The facts in that case of particular note are that there was significant discussion regarding parenting prior to the fertilisation procedure, the father attended the first and second ultrasounds, there were photographs of the parties opening gifts at the baby shower, the father was present at the birth, the father commenced playing child support from the time of the birth, the father spend regular time of the child and there were discussions of a second child [37].
(g)The High Court in Masson v Parson held that the meaning of “parent” is “a question of fact and agreed to be determined according to the ordinarily, temporary Australian understanding of parent and the relevant circumstances of the case at hand” [38]
(h)In support of the respondent’s claim that the father was a sperm donor only the respondent submits:
(i)They were friends.
(ii)The applicant told the respondent that he was doing it to help a friend out.
(iii)The applicant told a mutual friend that he was a donor helping out a friend.
(iv)The only reason the applicant attended two ultrasounds was because the respondent’s other support persons were not available.
(v)The respondent informed the midwife that her only support were family and close friends as this was a sperm donor situation.
(vi)The respondent attended the parenting course alone with the applicant telling the respondent that he was glad she wasn’t the only one there on her own.
(vii)The applicant informed the respondent that he only wanted visits every now and then and babysit.
(viii)The respondent has never entered into any discussions with the applicant regarding co-parenting or equal shared care for the child.
(ix)The applicant misrepresented himself as the respondent’s partner at the hospital.
(x)Mediation was not pursued as it was deemed inappropriate due to subregulation 25(2).
(xi)The applicant has not had contact with the child since birth and has not contributed to maintenance or parenting.
(xii)The evidence of the respondent should be preferred to that of the applicant.
(xiii)The respondent denied the proposal put forward by the applicant for shared care as evidenced by her text message.
(xiv)The facts of the current matter are vastly different to those in Masson v Parsons and it is the facts that determine the issue of whether a person is a “parent’ of a child.
(xv)The facts do not support the argument that the applicant is a parent for the purposes of the Family Law Act.
(xvi)There is no evidence on behalf of the applicant that there were any discussions as to the applicant being involved in the child’s life as a parent [39] to [61].
(i)If a finding is made that the applicant is not a parent then the proceedings should be dismissed [62].
(j)There is insufficient evidence to support that the applicant is a person concerned with the care, welfare and development of the child [63].
(k)The applicant has spent no time with the child and has no connection, relationship or any other nexus with the child other than being the biological father [64].
I now turn to the law.
IS THE APPLICANT A PARENT TO THE CHILD?
Section 60H does not have application in this matter as the respondent was not in a relationship at the time of conception.
The question then is whether the applicant is a parent?
The term “parent” is not defined in the Family Law Act 1975.
The lack of a definition does not normally cause concern as the vast majority of the matters before the court concern disputes between formerly married couples, de facto couples or boyfriend/girlfriend, boyfriend/boyfriend and girlfriend/girlfriend relationship couples and therefore the issue of whether a person is a parent does not arise.
This however is not the case here as:
(a)The parties were just friends.
(b)The applicant is gay and the respondent is of the view that she may be a lesbian.
(c)The respondent wanted a child even though she was not in a relationship and had investigated how that could occur.
(d)The applicant offered to father the child through artificial insemination.
(e)The respondent purchased an insemination kit.
(f)The applicant provided a semen sample and that resulted in a successful pregnancy.
So where does that leave the applicant?
Legal dictionary definitions such as parent is the “father or mother of a child” (Osborn’s Concise Law Dictionary) or “a natural or adoptive father or mother” (Butterworths Concise Australian Legal Dictionary) do little to assist where it is a matter of artificial insemination.
So what constitutes a parent?
The leading decision on what makes a sperm donor a parent for the purposes of the family law legislation is the High Court decision of Masson v Parsons & Ors [2019] HCA 21.
In that matter:
(a)The mother was in a same sex relationship.
(b)The father was a close friend.
(c)The father agreed to provide his semen to allow the mother to conceive through artificial insemination.
(d)At the time of conception the father believed he was fathering the child and would, as a parent, support and care for the child.
(e)The father’s name appeared on the birth certificate for the child.
(f)Although the child lived with the mother and her partner, the father took his role as the father seriously and had an extremely close and secure attachment with the child.
(g)The mother and her partner decided to relocate to Country F which would impact on the father’s ongoing relationship with the child.
(h)This resulted in court proceedings being commenced in the Family Court.
(i)At first instance the Family Court held that the father was the child’s parent and the mother and her partner were restrained from relocating the child to Country F.
(j)On appeal to the Full Court, the Full Court held that the father was not a parent of the child applying state law in New South Wales of the irrebuttable presumption that a biological father of a child conceived by a fertilisation process could not be categorised as a parent (as there was a gap in the law) and therefore the family court orders were overturned.
(k)The father obtained leave to appeal to the High Court.
(l)The High Court held that there was no gap in the legislation and as the Family Law Act1975 did not limit the categories of persons who could be deemed to be a parent of the child then it is in essence a factual exercise in each matter to determine if a father is a parent to the child.
(m)A finding was made that the father was a parent to the child and as such had equal parental responsibility which included making decisions as to whether the child was permitted to relocate to Country F.
In reaching their decision the High Court made the following findings:
(a)“The primary judge and the Full Court were correct in holding that s 60H is not exhaustive of the persons who may qualify as a parent of a child born as a result of an artificial conception procedure” [26].
(b)“Although the Family Law Act contains no definition of ‘parent’ as such, a court will not construe a provision in a way that departs from its natural and ordinary meaning unless it is plain that Parliament intended it to have some different meaning. Here, there is no basis in the text, structure or purpose of the legislation to suppose that Parliament intended the word ‘parent’ to have a meaning other than its natural and ordinary meaning” [26].
(c)“So to conclude does not mean that the only persons who, by law, have parental responsibilities are persons who are parents according to ordinary acceptation or are otherwise defined in the Family Law Act as parents. And it does not mean that the only persons who may seek parenting orders under s 61D are parents according to ordinary acceptation or are otherwise defined as parents. The range of permissible applicants is broader than that. But it is implicit in each of the provisions that have been mentioned that the Family Law Act proceeds from the premise that the word ‘parent’ refers to a parent within the ordinary meaning of that word except when and if an applicable provision of the Family Law Act otherwise provides” [27].
(d)“In re G (Children), Baroness Hale of Richmond observed in relation to comparable English legislation that, according to English contemporary conceptions of parenthood, "[t]here are at least three ways in which a person may be or become a natural parent of a child" depending on the circumstances of the particular case: genetically, gestationally and psychologically. That may also be true of the ordinary, accepted English meaning of ‘parent’ in this country, although it is unnecessary to reach a concluded view on that issue. The significance of her Ladyship's analysis for present purposes, however, is that, just as the question of parentage under the legislation with which she was concerned was one of fact and degree to be determined by applying contemporary conceptions of parenthood to the relevant circumstances, the question of whether a person qualifies under the Family Law Act as a parent according to the ordinary, accepted English meaning of ‘parent’ is a question of fact and degree to be determined according to the ordinary, contemporary Australian understanding of ‘parent’ and the relevant circumstances of the case at hand. The primary judge and the Full Court were correct so to hold” [29].
(e)“It remains that, apart from those specific provisions, the question of whether a person is a parent of a child born of an artificial conception procedure depends on whether the person is a parent of the child according to the ordinary, accepted English meaning of ‘parent’”[44].
(f)“And as has been explained, that is a question of fact and degree to be determined according to the ordinary, contemporary Australian understanding of ‘parent’ and the relevant circumstances of the case at hand” [44] (emphasis added).
(g)“To characterise the biological father of a child as a ‘sperm donor’ suggests that the man in question has relevantly done no more than provide his semen to facilitate an artificial conception procedure on the basis of an express or implied understanding that he is thereafter to have nothing to do with any child born as a result of the procedure. Those are not the facts of this case. Here, as has been found – and the finding is not disputed – the appellant provided his semen to facilitate the artificial conception of his daughter on the express or implied understanding that he would be the child's parent; that he would be registered on her birth certificate as her parent, as he is; and that he would, as her parent, support and care for her, as since her birth he has done. Accordingly, to characterise the appellant as a ‘sperm donor’ is in effect to ignore all but one of the facts and circumstances which, in this case, have been held to be determinative” [54].
(h)“It is unnecessary to decide whether a man who relevantly does no more than provide his semen to facilitate an artificial conception procedure that results in the birth of a child falls within the ordinary accepted meaning of the word ‘parent’. In the circumstances of this case, no reason has been shown to doubt the primary judge's conclusion that the appellant is a parent of his daughter” [55].
Conclusion
Before making my findings, comment must be made as to the lack of evidence provided by the respondent to support her position that the applicant in essence was nothing more than a sperm donor and therefore not a “parent” to the child.
The respondent could have, but did not provide the following:
(a)A copy of the birth certificate.
(b)The full history of the text messages between the parties regarding the child.
(c)An affidavit by the “mutual friend” who heard the comment made by the applicant that he was the sperm donor only.
(d)An affidavit by her support persons as to their being unable to attend her ultrasounds that the applicant subsequently attended.
(e)An affidavit by the maternal grandmother and other family members as to their involvement and observations of the situation.
(f)Subpoena material from the midwife as to the purported conversations the respondent had with the midwife as to the applicant being a sperm donor only.
(g)Subpoena material from the ultrasounds and other medical practitioners.
The applicant has also been remiss in supplying any independent evidence that supports facts disputed by the respondent.
Given these limitations I am unable to make any findings as to disputed facts including:
(a)The applicant making his donation of sperm contingent upon the applicant being involved in the parenting of the child.
(b)The applicant telling others that the applicant was the sperm donor only.
(c)The respondent telling others that the applicant was the sperm donor only.
(d)The applicant attending a meeting with the midwife.
I therefore must look to the undisputed facts in determining whether the applicant is to be considered as a parent to X.
I find having considered the undisputed facts and circumstances of this matter together with the evidence before me that the applicant is a “parent” to the child based on the following:
(a)The applicant always held and continues to hold the expectation that he will be involved with the child.
(b)The respondent informed the applicant of her pregnancy.
(c)The parties jointly informed others that the respondent was pregnant and the applicant was the biological father.
(d)The parties attended ultrasounds together and shared in the news that the child was a boy.
(e)The respondent initially kept the applicant informed as to the progress of her pregnancy.
(f)The parties discussed in exchanged banter the naming of the child.
(g)The respondent acknowledged the agreed name of “X” (although it was not subsequently used by the respondent) and told the applicant that she wanted part of the applicant’s name in the child’s name.
(h)The respondent, after the discussions as to the naming of the child in an email to the applicant on 9 February 2020 wrote “so I’m really thinking about not doing a baby shower, but just a small lunch on a Sunday with both our families from here to meet. And we can throw a big Christmas party for X to meet everyone. He will be 6 months then :) sounds good?” indicating the expectation that the applicant and his family would be actively involved with the child well after the birth of the child.
(i)The respondent openly discussed with the applicant his level of involvement with the child with the applicant confirming that he wanted visits and the opportunity to babysit. This is proof that the parties intended for the applicant to remain actively involved with the child.
(j)The respondent attended the hospital with flowers and chocolates to celebrate the birth of the child.
I find that the facts support a finding that it was the intention of the applicant as the biological father to be involved to some level in the parenting of the child after the child’s birth and that this expectation was initially fed into and supported by the respondent.
It was only once the boundaries were pushed by the applicant in what is now acknowledged by the applicant as being a somewhat misconceived view of future time with the child, that the applicant changed the goal posts by:
(a)Not engaging with the applicant.
(b)Moving away without providing the applicant with her new address.
(c)Not keeping the applicant informed as to the pregnancy.
(d)Not allowing the applicant at the birth of the child.
(e)Not allowing the applicant to visit the child in hospital.
(f)Refusing the applicant any time or communication with the child.
Nonetheless the applicant continued with his intent to be part of the child’s life by commencing parenting proceedings.
I find that the applicant cannot be penalised for the unilateral actions of the respondent in cutting the applicant out of the child’s life.
In conclusion I find that the applicant is a “parent” and has the right to bring parenting proceedings regarding X pursuant to section 65C.
FUTURE DIRECTION
The respondent needs to file a response setting out the orders she is seeking as to the applicant’s time with the child.
The parties need to complete intake in the contact centre.
The parties would benefit from a child dispute conference and once the Memorandum to Court has been released then a discussion can take place as to the applicant’s time with X.
I certify that the preceding forty-two (42) numbered paragraphs are a true copy of the Reasons for Judgment of Judge L. Turner. Dated: 20 July 2021
Key Legal Topics
Areas of Law
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Family Law
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Contract Law
Legal Concepts
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Offer and Acceptance
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Contract Formation
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Jurisdiction
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Procedural Fairness
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Remedies
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