Recently, the case of P.H.D. v. R.R.D. was decided by the Pennsylvania Superior Court. The P.H.D. case raises an issue that is discussed often among family law practitioners and has been reported in a number of appellate cases since the 1990s.
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Family Law
Error to Modify Custody at Contempt Hearing Without Petition Pending
The Legal Intelligencer
December 11, 2012
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