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BOWER v. REICH

No. 39813-0-I.

964 P.2d 359 (1997)

Barbara E. BOWER, Appellant, v. David McKim REICH, Respondent.

Court of Appeals of Washington, Division 1.

As Amended on Denial of Reconsideration January 29, 1998.

Attorney(s) appearing for the Case

Paul Seligmann, Seattle, for Appellant.

James Schermer, Seattle, for Respondent.

BECKER, Judge.

Under the Parenting Act of 1987, as In Re Littlefield recently held, a trial court entering an initial parenting plan may not "order a primary residential parent to live in a particular geographic area in order to facilitate frequent contact between the child and the other parent".1 Guided by Littlefield, we hold a primary residential parent may invoke the "minor modification...

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