The recent case of W.C.F. v. M.G., 115 A.3d 323 (Pa. Super. 2015), addresses numerous issues often faced by family law practitioners. The relevant factors of the case are as follows: W.C.F. (the father) and M.G. (the mother) were previously married and had one child. The parents of the mother (who is a native of Malaysia) resided with the parties in the parties’ apartment since prior to the parties’ child being born. Once the child was born, according to the opinion, the maternal grandmother had been the primary caretaker of the child. As reflected in the opinion: “As a result of father’s belief that mother’s family, in particular maternal grandmother, was blocking his attempts to bond with child, the parties agreed that maternal grandparents would move out of the parties’ apartment and obtain their own residence.” When the maternal grandparents moved out of the apartment, the mother took the child and vacated with her parents.

The date after the mother took the child from the apartment to live with her parents, the father filed a complaint for shared legal and physical custody of the child. The mother also filed a pleading with the court seeking for a divorce and confirmation of legal and primary physical custody of the child.

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