MATTER OF IAN G.

78/15.

180 A.D.3d 474 (2020)

119 N.Y.S.3d 95

2020 NY Slip Op 00986

In the Matter of Ian G. and Others, Children Alleged to be Neglected. Simon G., Appellant; Administration for Children's Services, Respondent. Victoria G., Nonparty Respondent. Victoria G., Respondent, v. Simon G., Appellant.

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

Decided February 11, 2020.


Family Court properly denied the father's request to appear by phone for the final day of hearings. The record reflects the court's efforts to accommodate the father's needs throughout the proceedings, for instance, ensuring that hearings did not take place in the morning, per his request. The father does not explain why he waited until two days before the April 20, 2018 hearing to make the motion, and his delay was unreasonable. His request did not arise from an emergency...

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