MATTER OF HILIANA R. v. CESAR A.P.J.

7845.

167 A.D.3d 463 (2018)

87 N.Y.S.3d 478

2018 NY Slip Op 08439

In the Matter of Hiliana R., Respondent, v. Cesar A.P.J., Appellant.

Appellate Division of the Supreme Court of New York, First Department.

Decided December 11, 2018.


Although the father did not give written consent to have the referee determine the petition, as required by CPLR 4317 (a), the father implicitly consented by actively participating in the proceedings before the referee, including by testifying and cross-examining the mother, without challenging the referee's jurisdiction (see Matter of Hui C. v Jian Xing Z., 132 A.D.3d 427 [1st Dept 2015...

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