Partos and Merritt

FAMILY COURT OF AUSTRALIA

PARTOS & MERRITT

[2017] FamCA 205

FAMILY LAW – CHILDREN – PARENTING – CONTRAVENTION – Where the father alleges five counts of contravention against the mother – Where the mother is found to have contravened without reasonable excuse on two counts – Where circumstances mitigate the seriousness of the contraventions

Family Law Act 1975 (Cth)

APPLICANT:

Mr Partos

RESPONDENT:

Ms Merritt

FILE NUMBER:

BRC

1985

2007

DATE DELIVERED:

7 April 2017

PLACE DELIVERED:

Brisbane

PLACE HEARD:

Brisbane

JUDGMENT OF:

Forrest J

HEARING DATE:

3 April 2017

REPRESENTATION

THE APPLICANT:

Litigant in Person

THE RESPONDENT:

Litigant in Person

Orders

That paragraph 5(b)(iv) of the parenting Orders of 11 September 2015 be discharged and replaced with the following paragraph as a new paragraph 5(b)(iv):
The father taking the child to all of his extra-curricular activities scheduled during that weekend, including any football game or games, with the mother to give the father details in writing of any such activities and games scheduled during that weekend at the father’s written request if she is aware of those details at the time of his request or if she is not aware of those details when he first requests them then as soon after his request as she does become aware of those details.
That paragraph 6(a) of the parenting Orders of 11 September 2015 be discharged and replaced with the following paragraph as a new paragraph 6(a):
By call made between 6.00 pm and 6.30 pm New South Wales time each Wednesday and Sunday and other special days (as defined in the next sub-paragraph), such communication to be facilitated by the father calling the child on the mother’s land line or mobile telephone number and the mother ensuring that the child takes the call and also by the mother using her best endeavours to facilitate the use of video call technology at her end if the father wants to use it for each such call, using Skype or Facetime, or such other carrier as they may agree, and also by the mother ensuring, if it is at all practicable at that time, that the child is able to talk to his father in private.
That paragraph 7(a) of the parenting Orders of 11 September 2015 be discharged and replaced with the following paragraph as a new paragraph 7(a):
By call made between 6.00 pm and 6.30 pm New South Wales time each Wednesday and Sunday and other special days (as defined in the next sub-paragraph), such communication to be facilitated by the mother calling the child on the father’s land line or mobile telephone number and the father ensuring that the child takes the call and also by the father using his best endeavours to facilitate the use of video call technology at his end if the mother wants to use it for each such call, using Skype or Facetime, or such other carrier as they may agree, and also by the father ensuring, if it is at all practicable at that time, that the child is able to talk to his mother in private.
That consequent upon my findings that the mother contravened Orders providing for communication between the father and the child, the father shall have two compensatory calls with the child as follows:
(a)By call made between 6.00 pm and 6.30 pm New South Wales time on the first and second Fridays of the child’s second school term this year that the child is not otherwise in the care of the father, such communication to be facilitated by the father calling the child on the mother’s land line or mobile telephone number and the mother ensuring that the child takes the call and also by the mother using her best endeavours to facilitate the use of video call technology at her end if the father wants to use it for each such call, using Skype or Facetime, or such other carrier as they may agree, and also by the mother ensuring, if it is at all practicable at that time, that the child is able to talk to his father in private.

Note: The form of the order is subject to the entry of the order in the Court’s records.

IT IS NOTED that publication of this judgment by this Court under the pseudonym Partos & Merritt has been approved by the Chief Justice pursuant to s 121(9)(g) of the Family Law Act 1975 (Cth).

Note: This copy of the Court’s Reasons for Judgment may be subject to review to remedy minor typographical or grammatical errors (r 17.02A(b) of the Family Law Rules 2004 (Cth)), or to record a variation to the order pursuant to r 17.02 Family Law Rules 2004 (Cth).

FAMILY COURT OF AUSTRALIA AT BRISBANE

FILE NUMBER: BRC 1985 of 2007

Mr Partos

Applicant

And

Ms Merritt

Respondent

REASONS FOR JUDGMENT

On 11 September 2015, I made final parenting orders after a two day trial involving the parties in this matter and an Independent Children’s Lawyer. The child, the subject of the orders, C (the child), who is almost 11 years old, has not known life without conflict between his parents about their co-parenting of him.
This is the second contravention application between the parents since those orders were made eighteen months ago and at least the fourth such application in the history of their parenting litigation in this Court.
In October last year I found that the father had contravened one of the primary parenting orders without reasonable excuse and I ordered that he enter into a bond to be of good behaviour for nine months. He agreed to do that.
On 23 November, 2016, the father filed this contravention application against the mother, having foreshadowed that he was going to when I was hearing the mother’s contravention application against him.

The Contraventions alleged

The father, who is without legal representation, alleged contraventions under five separate specific counts. Under one of those, he included multiple alleged contraventions.

Count 1

The father alleged contravention of Order (5)(b). That Order provides for the child to spend time with the father, amongst other times, for up to two weekends during each school term at the father’s election, on certain conditions.
One of those conditions, relevantly, is that the father picks the child up from school on the Friday afternoon and returns him to school on the following Monday morning.
In purported activation of the provisions of the relevant part of the Order, the father gave the mother notice that he elected to have the child with him for the Easter weekend in 2016 which was 25, 26, 27, 28 March. He told the mother he would pick the child up from school on the Thursday afternoon and drop him back to school on the Tuesday morning. The mother responded, telling him that she did not agree that his request fitted the correct interpretation of the relevant Order and that she would not let the child spend the four day Easter long weekend with him. The autumn school holidays were to commence within two weeks and pursuant to the Orders the child would be spending all of those holidays with the father.
The father then wrote an eight page email response to the mother in which he set out his views and tried to persuade her to let the child spend Easter with him. He asked her to consider letting the child spend from Friday afternoon to Monday morning with him over that weekend, expecting the changeovers still to take place at the boy’s school that would be shut on those days. The mother again responded with the same answer.
At the commencement of the hearing before me on Monday 3 March, 2017, I called for submissions as to whether the agreed facts disclosed an actual contravention of the relevant order. The mother submitted that they did not on a correct interpretation of the relevant order. The father still submitted that the mother was in contravention of the Order.
I then summarily dismissed that part of the father’s contravention application and gave oral reasons at the time. I considered that the relevant Order only provided for the child to spend weekends with the father during school term from after school on a Friday to before school on a Monday and that the father could, therefore, only nominate weekends when the Friday was a school day and the Monday was a school day. The mother does not contravene that Order by not agreeing to the child spending any other weekends nominated by the father, such as three or four day long weekends.

Count 2

The father alleged the mother contravened Order (13) of the primary Orders. That Order provides:
That each parent shall keep the other parent informed in writing at all times of their residential address, email address and contact telephone number or numbers, and shall notify the other of any change to any of those within 48 hours of knowing what any such change is or is going to be.
The mother moved from the southern outskirts of Brisbane to live in northern New South Wales in late 2015. That had been part of the dispute that was determined with the primary Orders made in September that year. The Court permitted her to move the child with her.
The father alleged that when she moved she failed to inform him in writing of her new residential address within 48 hours of knowing of the prospective change as required by Order (13).
The mother accepted that she had contravened that order. She said that she had overlooked the requirement as she believed that the father already knew where she and the child were moving to. She asserted that the child had told her that his father had shown him photos of the house that they were moving to and discussed the property with him. However, she accepted that she had not checked with the father whether that was correct and had not asked him if he still required her to give him the address as the Orders provided for.
In those circumstances, I am satisfied that she did not make a reasonable attempt to comply with the Order as a reasonable attempt would have been to at least have checked with the father whether he did have the address and whether he still wanted her to provide it to him as the Order required.
However, in his evidence, the father confirmed the following:
(i)He had searched online for properties for sale in the local area where the mother had said she would be moving to, before she had moved;
(ii)He had found few properties for sale in that area;
(iii)He had shown the child photos of the property or properties he had found in his online research;
(iv)C told him that he thought they were moving into one of those properties, which he identified;
(v)He was not completely certain, on that information, that the property that had been identified by the child was the one that the mother and the child were moving into;
(vi)After that, he did not ever ask or request the mother to comply with the requirement of the Order to provide him with her new residential address in writing;
(vii)He did not have any reason for needing to know the mother’s new residential address, in any event, save in respect of the chance of the child calling him in an emergency that might require him to know the address.
After giving all of that evidence, I asked the father why, in those circumstances, he was seeking to have the mother found to have contravened this particular Order. He made it clear that he was seeking to prove that the mother contravened a number of parts of the primary Orders to support a submission that the primary Orders should be changed to give him more time with the child. I will return to this subject later.

Count 3

The father alleged that the mother had contravened the requirement contained in Order (6)(b) that when the father and child communicate by video call or telephone that she ensures the child is able to talk to the father in private. He alleged that this happened on 21 August, 2016, and that this contravention is “continuing”.
The father alleged that the mother “interfered” with the privacy of the communication between him and the child on that date by “ordering” the child not to talk with the father about a strategy computer game on the Ipad that the child plays when he is with the father. The father said that the child “likes to get updates from [the father] whilst he is away and to give [his father] directions to advance his clan’s buildings etc”.
The mother gave evidence about the matter. She denied contravening this part of the Order as alleged. She identified the game that the father was talking about as “Clash of Clans”. She said that the child is not allowed to play that game in their home. She told the Court that her parenting decision about this was based on the fact that it is an online game that permits the player to interact and talk with third party strangers who are also online playing the game at the time and that she does not consider that to be safe for the child to be exposed to.
She said that she is aware that the child plays the game when he is spending time with the father and that she cannot stop that. She said that she believes that the father knows that the child is not permitted to play the game when he is in his mother’s care. Whilst the father conceded in evidence that he knows that, it was not clear to me when he first learned that.
The mother said that on the evening in question, when she is alleged to have contravened the privacy provision of the Order, the child was in his bedroom at one end of their home, in private, communicating with his father. The mother said she was in the kitchen in the middle of the home when she heard the child loudly and excitedly talking to his father and she was able to make out that the child was playing ‘Clash of Clans’ with his father whilst they were communicating via an online video call. She was not happy about that given that her rule is that he does not play that game in her household, so she went to his room and looked at the child and gave him a sign to desist from the game.
The mother was not seriously challenged in cross-examination on that evidence. I accept it as the truthful account of what occurred that evening.
The father’s submission, as I understood it, was that the mother, by telling the boy to desist from the game and demonstrating that she knew what he was doing, contravened the obligation to give the child and the father privacy during the calls. The father went on to submit, as I understood it, that he should be allowed to communicate and interact with the boy during these calls as he sees fit and that the privacy obligation imposed upon the mother requires her to understand and respect that, without interference, whether she would like what the child is doing during those calls or not.
The father made it absolutely clear to the Court that he was not concerned that the mother did not let the child play ‘Clash of Clans’ whilst in her care. He did not consider it to be problematic that he engaged the child in ‘Clash of Clans’ when communicating with him, even though the boy was in his mother’s home and the father knew that the mother did not permit him to play that game in her home. The father went on to give evidence that during the video calls, it is he, the father, who is actually playing the computer game for the child at his end of the call and that he is merely showing the screen to the child and discussing moves and strategy with him during the call. He argued that, thereby, the boy is not playing the game but that he is, so it cannot be seen to be a problem. The father further asserted, out of some apparent regard for the mother’s position, that when he plays the game with the boy during such video calls that the boy is safe as he does not communicate on line with third party strangers.
I must say that I became satisfied that the father was using this issue of the game of ‘Clash of Clans’ as a means of subtly undermining the child’s relationship with his mother and of further endearing himself to the boy. I consider that he merely paid lip service to the idea of respecting the mother’s parental right to determine what the child played in her household whilst in her care.
Whilst going to the child’s room on the evening in question and telling him to desist from playing ‘Clash of Clans’ as she did does amount to an interference with the privacy of the communication between father and son on that night, I consider the mother has a reasonable excuse for such interference. She overheard the loud and excited boy from a distance whilst she was giving him privacy. She realised he was playing or interacting with his father on a game that he was not permitted to play in her home and she went and asked the child to desist. She then went away again. I do not consider that to be an unreasonable reaction from the mother. Accordingly, I consider that she has, in the circumstances, reasonable excuse for contravening the obligation to provide privacy on that night.
I do not accept the father’s further argument that the mother’s expectation that the father respect her position in respect of the child not playing ‘Clash of Clans’ whilst in her household is an ongoing and continuing contravention of the obligation to give privacy to the father and the child for their calls. Whether the father agrees with the mother’s parenting decision about this or not, it is not unreasonable for him to abide by it whilst the child is in the mother’s care.
I am not satisfied that the father has proven his case that the mother contravened the privacy obligation on 21 August, 2016, without reasonable excuse, or that she is doing so on a continuing basis by expecting him not to play ‘Clash of Clans’ with the child during their video or phone communications when the child is in her care.
However, other evidence came out during the hearing that suggests there are some circumstances occurring where the child and the father are not given privacy during their calls.
Pursuant to the Orders, the father can call the child each Sunday and Wednesday and other special days between 6:00 pm and 6:30 pm NSW time to speak with him by video call or phone call if video call is not available. There is no disagreement that sometimes when the father has called, the mother and the child have been in the car travelling. The child’s football training obligations were cited as at least one explanation for that. When the father calls and the boy and his mother are together driving in a car, clearly the mother has not been able to give them the privacy that the Order requires her to ensure.
The mother explained and the father conceded that there are times when he does not ring between 6:00 pm and 6:30 pm. The father attributed that to getting on with his life and sometimes simply being confronted by circumstances that make it difficult or impossible to call the child during the time frame provided for in the orders.
The mother said that as a consequence of experiencing waiting around for calls that do not come, she and the child have got to the point of just getting on with their lives and taking the calls when they come, wherever they are. Consequently, in these circumstances, too, she has not always been able to ensure that the calls are taken with privacy ensured.
This concerns me, particularly in the light of the extremely poor relationship between the mother and the father in this case and the potential for such circumstances to lead to further contravention applications in the future. I will return to this subject later.

Count 4

The father further alleged that the mother contravened Order (6)(a) when she did not facilitate communication between him and the child when he called on the following dates:
·31 August 2015
·4 September 2015
·13 September 2015
·29 November 2015
·23 December 2015
·9 February 2016
·16 March 2016
·30 March 2016
·1 June 2016
·29 July 2016
As the first two dates were prior to the Order alleged to have been contravened, I determined not to consider those alleged contraventions.

The father said that on Sunday, 13 September, 2015, he had called to speak with the child but was not able to get through to him. He conceded that later that same evening he got a phone call back from the child and was able to speak with him but did not get to video call with him.
The mother, who was also unrepresented at the hearing, filed an affidavit in which she denied that she had contravened as alleged.
The father asserted that he had kept details of the dates and the failure to get through to the child in a journal from which he had taken the details when preparing this application. I accept that evidence, though the mother made the point that the father did not produce the journal in support of his own evidence.
The mother could not be specific with respect to dates and her denial was a general denial of contravention as alleged in respect of the communication issues. On balance, I accept the father’s evidence on this point.
I find that the mother did not facilitate the call that evening as required by the Order and that she has not made out reasonable excuse. However, as a fact in mitigation, I accept that she did cause the child to call his father later that same day to speak with him on the telephone, as the father conceded.
The father further alleged that on Sunday 29 November, 2015, he telephoned and texted and was not able to get on to speak with the child. The mother, in response, told the Court that they had moved to their new residence in NSW on Saturday, 28 November and that when the father called on Sunday 29, he was unable to have a conversation with the child as their home phone line had not yet been connected and her Telstra Mobile phone had no reception. She said that she had tried to have the land line connected before the move but it had not been done by Telstra. She said that she changed mobile provider to Optus on Monday, 30 November and that on that night, the father and the boy had a video skype call uninterrupted. I accept that evidence as the mother’s recall around the particular event was quite particular and the father did not challenge her evidence in cross-examination. I consider that she had reasonable excuse for not facilitating the communication as ordered on Sunday 29 November, 2015.
The father alleged that the mother contravened on Wednesday 23 December, 2015. He said that he rang during the ordered time frame from New Zealand and got through and was hung up on by the mother. He said he called back but was then outside the Court ordered time frame and the mother would not let him speak with the child.
The mother simply denies the allegations. There was no real challenge to the father’s evidence though and the mother did concede that there are times when the father rings outside the Court ordered time frame when she does not let him speak with the child.
Again, on balance, I accept the father’s evidence and find that the mother did contravene the order on this occasion and that she did not have reasonable excuse for doing so.
The 9^th of February 2016 was a Tuesday. The father conceded he must have made a mistake in respect of listing that date. I will not consider that alleged contravention any further.
The father alleges that on Wednesday, 16 March, 2016, he rang twice to speak to the child and sent a text but could not get through to speak to him. He said that more than an hour later he received a call back from the child and spoke with him.
The mother simply denied the alleged contravention but said nothing more of that date.
I accept the father’s evidence and find that the mother contravened and did not establish a reasonable excuse. I will consider the fact that she clearly caused the child to call the father back the same night as a fact in mitigation.
The father alleges that on Tuesday, 30 March, 2016 he rang to communicate with the child. He said that he was not able to have a video call and was told this was because the child was out in the garden feeding animals. The mother made a simple denial of contravention, though conceded occasions when the boy was out in the yard at the time of calls.
I accept that the mother has not established a reasonable excuse for not complying with the obligation to ensure a video call took place at the time that night. I will take the fact that the father concedes he spoke with the boy by phone instead as a fact in mitigation.
The father alleges that he was only able to speak with the child by phone on 1 June, 2016 and not by video call. He said that he was told by the mother that the child had dropped her laptop computer and was not allowed to use it. The mother simply denied contravening in this way but went on to say that the only time the father did not get a video call with the child was when technical issues did not permit it or when the child has not wanted to skype and was content to talk on the phone. She confirmed that she has a laptop computer, a mobile telephone with internet access and an Ipad.
I do not accept that video calls need not be facilitated simply when the child himself says he does not want to have a video call. The obligation is on the mother to ensure they happen and that does not mean simply abiding by what the child may or may not want. On this occasion, I accept the father’s evidence, again noting that he kept a journal and had taken the information from his journal when preparing the affidavit. I find that the mother contravened her obligation to ensure a video call and made no reasonable effort to ensure it happened. That she permitted a phone call though, is a fact in mitigation that will be taken into account.
The father alleged that he called the child on the father’s own birthday in 2016 and was only able to talk on the phone with him rather than video call with him. He said he was told that the Ipad was not charged.
Again, the mother denied contravening that night.
I accept the father’s evidence and am satisfied that the mother contravened by not making a reasonable attempt to put the boy on to a video call. Her Ipad may have had a flat battery but her computer or her phone could have been used. That he was able to speak with the boy by phone though, is a fact in mitigation that I will take into account.

Count 5

The father alleged that on 8 May, 2016, the mother also contravened an obligation imposed upon her by Order (5)(b)(vi) in that she refused to provide him with details of the child’s football games when he asked her to.
That Order is one of the conditions upon which the father is able to nominate two weekends during school term upon which the child shall spend time with him. It provides that such nominations are conditional upon:
The father taking the child to all of his extra-curricular activities scheduled during that weekend, including any football game, with the mother to give the father details in writing of any such activities and games scheduled during that weekend at the father’s request or as soon after his nomination of that weekend as she learns of the scheduled extracurricular activity or game, whichever is the earlier.
The father alleges, and there is no dispute that he sent an email to the mother on 6 May, 2016 saying to her:
Please note and acknowledge the child will be spending the weekends commencing 20^th May and 10 June with me.
Likewise, there is no dispute that he sent her another one on 8 May, 2016 saying:
Please provide forthwith details of any extra curricular activities.
The mother wrote back to him on the same day saying:
I can absolutely guarantee you that if you insist on communicating with me in a disrespectful and/or offensive manner/tone, I will not respond. You do it in your emails, you do it in your texts. I am not here to be ordered around and instructed by you.
The mother sent him another email on 17 May saying:
[C] is playing at 9:00 am at [U Park, V Town] on 21/5/16. He needs to be there 45 minutes prior to game commencement for training.
The mother denied contravening the Order and gave evidence that on 8 May, 2016, when the father asked her for the details, she did not know them and had no means of finding them out. She said that when she was informed of the details on 17 May, she emailed them to the father. She said that it is often the case during the child’s football season that the parents are only given details of the venue and the game time a few days before the game is to take place. I accept that.
In the face of that evidence, the father still submitted that the strict wording of the Order required the mother to give the father the details when he requested them. I acknowledged that might be the case having regard to the particular wording but asked him whether the mother might not be considered to have a reasonable excuse for not giving him the details when he asked for them if I accepted the truth of her evidence that she did not have those details then and had no means of getting them before 17 May. Incredibly, the father maintained his submission that she had contravened the Order. He argued that she should have been able to get the information when he requested it, but there was absolutely no evidence before me to support that submission.
I am satisfied that the mother had a reasonable excuse for not complying with the obligation imposed by this part of the Order.

The Outcome and the Consequences

I have found that the mother contravened the obligation to provide the father with her residential address, but that there were circumstances that mitigate the seriousness of that contravention.
I have found that the mother contravened the obligations around video and phone communication on five specific dates, but that on four out of those five the father and the boy were able to speak by phone at the very least and that on only one occasion did the father not get to speak to the child on the day he called to speak with him.
I have found that the mother contravened the order about giving the father details of the boy’s football games but that she had a reasonable excuse for that contravention.
Although this is the second occasion in several years on which I have found the mother to have contravened parenting orders without reasonable excuse, the father maintained a submission that he was not interested in having consequences visited upon the mother for her contraventions but rather was trying to ensure that he got to spend more time with the child. He maintained this position at the same time as confirming that the boy had spent all the time with him that was provided for in my September, 2015 Orders, since those Orders were made.
The father then handed me a draft of my September 2015 Orders with proposed amendments that he wanted me to make to them, presumably pursuant to the power conferred by s 70NBA of Part VII Division 13A of the Family Law Act 1975.
The amendments his draft proposed were many. They included discharging the Order conferring sole parental responsibility on the mother. They included what were clearly the most important ones to the father – the discretion to determine whether he took the child to football games on the weekends when he is spending time with him during school term and the right to be able to ring and speak with the child at any time the father wants.
When I asked the father what his position might be in the event that I was not persuaded to change the primary Orders as he proposed, he then immediately submitted that the mother should be put on a bond to be of good behaviour in the very least, just like he was last year.
Having regard to my knowledge of the this matter gained over the years that it has been coming before me, and mindful of all of the matters that must be, if relevant, considered by me pursuant to s 70NBA, I am satisfied that the best interests of the child require some minor amendments to the Orders that I made in September, 2015, particularly so that there is less prospect for the mother to be in contravention of an order in circumstances where she might indeed have a reasonable excuse in any event. The obligation to provide details about football games when the father requests that of her, whether or not she has access to that information at the time is a clear example of such a provision. I intend to vary that. The obligations around facilitating communication also should be made clearer and less open to contravention applications being unnecessarily brought, in my judgment. I will make such amendments.
Otherwise, I am not persuaded by the father that the child’s best interests require any further amendment to the primary Orders, consequential to the contraventions I have found. As I told the father during the hearing, contravention applications are not primarily aimed at effecting variation to existing primary Orders. That is properly done through application for variation made in the way such applications are usually made in this Court.
In addition, I am quite satisfied that although it is the second contravention found against the mother by me, that it is nevertheless more appropriate for the contraventions that I have found to have occurred to be dealt with under Subdivision E of Division 13A of the Act as being less serious contraventions.
Although I have found that the mother did contravene some parts of the primary Orders, I am satisfied that none of those contraventions prevented the father from having the child spend time with him as ordered or seriously interfered with the child’s relationship with the father. I am not at all persuaded that any of those contraventions amounted to wilful disobedience by the mother of the Court’s authority with the intention of harming the child’s relationship with the father. I am satisfied that as much as the mother has dislike for the father, that she is now doing much better at accepting the need for the child to maintain a relationship with him, and facilitating it. I am also satisfied that the father’s motivation for bringing this application included a desire to respond in kind to the fact that the mother had brought a contravention application against him and herself tells him she expects strict adherence to the letter of the primary Orders.
I do not consider it necessary to require the mother to enter into a bond to be of good behaviour. She is, I am satisfied, suitably aware of the need to comply with the obligations imposed upon her by the primary Orders of this Court.
On the evidence, I have found that the father missed a video call with the child in December, 2015. I will simply make an Order providing for him to have two additional calls with the child to compensate him for that lost one.
It is to be hoped, for the child’s well-being, that these parents might soon be able to put their enmity for each other aside and to begin to co-parent with the child’s best interests solely in mind.
I make the Orders set out at the commencement of these reasons.

I certify that the preceding eighty-one (81) paragraphs are a true copy of the reasons for judgment of the Honourable Justice Forrest delivered on 7 April 2017.

Associate:

Date: 7 April 2017

[2017] FamCA 205

7 April 2017

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Family Law

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Procedural Fairness