Appellate Division of the Supreme Court of the State of New York July 11, 2012 (Davis v. Pignataro)
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United States · · · 11-07-2012
“ ‘In order to modify an existing custody or visitation arrangement, there must be a showing that there has been a change in circumstances such that modification is required to protect the best interests of the child’ ” (Matter of Peralta v Irrizary, 76 AD3d 561, 562 [2010], quoting Matter of Arduino v Ayuso, 70 AD3d 682, 682 [2010]).
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