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10-Jan-2020 04:44

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The facilitation and encouragement of such relationship is one of the twelve best interest factors, and based on the testimony presented, the problems between the parties are having asignificant effect on the well-being of the children involved in this case.

Therefore, the Court finds proper cause exists to revisit the current custody order.[Footnote omitted.]It is arguable that defendant has waived his argument that there was not proper cause orchange of circumstances sufficient to revisit the custody order by asserting in his petition forchange of custody that there was proper cause to revisit the custody issue.

Foskett v Foskett, 247 Mich App 1, 6; 634 NW2d 363(2001).

When amovant has demonstrated such proper cause, the trial court can then engage in areevaluation of the statutory best interest factors.* * *[I]n order to establish a “change of circumstances,” a movant must prove that,since the entry of the last custody order, the conditions surrounding custody of thechild, which have or could have a significant effect on the child’s well-being,have materially changed.