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undertakings

Case Update (2020): In re MVU; Hague Abduction Convention and Article 13(b) grave risk due to domestic violence towards the taking parent

April 22, 2021

In the recent case of In re MVU, the Appellate Court of Illinois affirmed an order refusing return of a minor child to its habitual residence of Mexico because that would present a grave risk of harm to the child based on the father's domestic violence of the mother.  The court in opining … Read More about Case Update (2020): In re MVU; Hague Abduction Convention and Article 13(b) grave risk due to domestic violence towards the taking parent

Category iconChild Abduction,  domestic violence,  Grave Risk,  Hague Abduction Convention,  harm,  undertakings

Case Update (2020): Saada v. Golan; ameliorative measures, grave risk of harm under the Hague Abduction Convention, guarantees of performance

April 22, 2021

The Second Circuit addressed a 2nd appeal in the Saada v. Golan case on October 28, 2020, and affirmed Judge Donnelly's May 5, 2020 order to return the minor child to Italy.  As a reminder, this family has been litigating the father's Hague Abduction Convention return petition up and down the … Read More about Case Update (2020): Saada v. Golan; ameliorative measures, grave risk of harm under the Hague Abduction Convention, guarantees of performance

Category iconameliorative measures,  Child Abduction,  Enforceability,  Grave Risk,  Hague Abduction Convention,  performance,  psychological risk,  undertakings

Case Update (2020): Valles Rubio v. Veintimilla Castro; Grave Risk in Hague Abduction Case, and ameliorative measures

April 22, 2021

On May 11, 2020,  the Second Circuit Court of Appeals affirmed the return of a minor child to Ecuador in the case of Valles Rubio v. Veintimilla Castro, 813 Fed.Appx. 619 (2020).  The key issue on appeal revolved around the grave risk of harm to the minor child if returned to Ecuador, and … Read More about Case Update (2020): Valles Rubio v. Veintimilla Castro; Grave Risk in Hague Abduction Case, and ameliorative measures

Category icon1980 Convention,  abduction,  abuse,  Case Update,  Child Abduction,  compliance,  Enforceability,  enforcement,  Grave Risk,  undertakings

Case Update (2020): Radu v. Shon; Hague Abduction Convention and the Grave Risk of Harm

April 22, 2021

On September 16, 2020, the U.S. District Court for the District of Arizona returned the parties' children to their habitual residence of Germany.  In the case of Radu v. Shon, the Respondent Mother (Shon) conceded that her removal of the children from Germany in June 2019 was wrongful.  … Read More about Case Update (2020): Radu v. Shon; Hague Abduction Convention and the Grave Risk of Harm

Category icon1980 Convention,  abduction,  abuse,  Case Update,  Child Abduction,  Enforceability,  Grave Risk,  undertakings

Case Update (2020): Grano v. Martin; Hague Abduction Convention, Habitual Residence, Grave Risk & Undertakings

April 22, 2021

The U.S. Court of Appeals for the 2nd Circuit recently affirmed a return order issued pursuant to the Hague Abduction Convention in the Grano v. Martin matter.  The Respondent Mother appealed on three points.  First, she argued that the trial court misapplied the Monasky v. Taglieri test … Read More about Case Update (2020): Grano v. Martin; Hague Abduction Convention, Habitual Residence, Grave Risk & Undertakings

Category icon1980 Convention,  Case Update,  Child Abduction,  Evidence,  Grave Risk,  Habitual Residence,  undertakings

Case Update (2020): Saada v. Golan; Undertakings to Ameliorate a Grave Risk and the 1980 Convention

April 22, 2021

In 2019, the 2nd Circuit Court of Appeals addressed the issue of undertakings in a 1980 Hague Child Abduction Convention case.  In the case of Saada v. Golan, 930 F.3d 533 (2nd Cir 2019), a mother was accused of wrongfully retaining the parties’ minor child in New York after visiting for a … Read More about Case Update (2020): Saada v. Golan; Undertakings to Ameliorate a Grave Risk and the 1980 Convention

Category icon1980 Convention,  Child Abduction,  Grave Risk,  undertakings,  wrongful retention

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