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M.N. v. A.N. (TRO)
Hawaii Intermediate Court of Appeals (SDO)
June 20, 2017

Stipulated custody and visitation orders contained in an Order for Protection are temporary orders, under HRS 586-5.5, subject to modification later in the appropriate custody matter (divorce or paternity). A party seeking to vacate an Order for Protection, will not find relief via a claim for breach of contract.

“… even if the parties contemplated visitation rights as being part of the Order for Protection, HRS 586-5.5 clearly establishes that such rights would
be temporary.”

Opinion here: http://www.courts.state.hi.us/wp-content/uploads/2017/06/CAAP-16-0000585sdo.pdf

Author: Justin L. Sturdivant, Esq.


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