Although the Special Term had continuing jurisdiction to modify the judgment of divorce in respect of custody and visitation of the child of the parties, some notice of either an application by the defendant or other adverse party or of an intention by the Special Term to change custody provision must be given to the plaintiff with an opportunity to meet that issue by adducing proof. (Allers v. Allers, 236 N.Y. 54; Hartenstein v. Hartenstein, 286 App. Div. 868...
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