Modification of child custody and visitation orders require a substantial, material change of circumstances since the Court's prior custody decision. Additionally, the movant must demonstrate that the children's best interest justify a change in custody. In Chamberlain v. Eisinger, the Florida Court of Appeal had a case before it in which a judgment was entered in Maryland. The Maryland trial court gave the Mother custody of the four children. After the divorce was granted the Father moved to Florida. In 2008, the Mother and Father agreed that the Father would have custody of the oldest daughter. In 2009, the Mother and Father agreed that the Mother would have custody of the youngest daughter and the two sons. In 2010, the Mother moved to Florida. The same month that the Mother moved to Florida, the trial court in Maryland entered a new order specifying times and dates for visitation. However, the new order was based upon the premise that the Mother and the younger children were living in Maryland.
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