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Outline a custody relocation motion
Builds a relocation motion or objection organized around your state's own relocation test: notice questions first, every factor pinned to evidence, and a long-distance parenting plan concrete enough that a judge could sign it.
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I. Notice and procedure: confirm before anything else.
- Relocation notice mailed 3/2/26; objection filed 3/24/26. Confirm against current RCW 26.09.440: required contents of the notice, permitted method of delivery, the objection period, and whether the objection was timely. [UNVERIFIED - pull the current statute; do not rely on the 30-day figure in my file memo.]
- Confirm whether an objection filed on 3/24 stays the relocation automatically or requires a separate motion.
II. Governing test. Washington's Child Relocation Act applies a rebuttable presumption that relocation will be permitted, and the objecting parent bears the burden of rebutting it against enumerated factors. [UNVERIFIED - confirm the presumption, the burden, and the current factor list before drafting the brief. Do not argue from this framing until verified.]
III. Statement of facts.
- 2023 final parenting plan: alternating weekends plus Tuesday and Thursday dinners, approximately 35% of overnights.
- Exchange log (Ex. C) shows Mr. Ellery exercised 21 of his 26 alternating-weekend blocks in 2025 and 19 of 24 Thursday dinners in the second half of the year. Concede this. It is true and it is the strongest thing about his objection.
- Written offer from Duke University dated 2/18/26, Senior Research Scientist, $148,000, start date 8/15/26 (Ex. A). Current salary $91,400 (Ex. B).
IV. Factor: relative strength and stability of the child's relationship with each parent.
- Fact: twins have lived primarily with mother since separation in 2022; she manages medical, school, and activities. Source: school and pediatric records, Ex. F-G. Witness: Ms. Kalra (mother).
- Fact: father's relationship is real and regularly exercised. Source: Ex. C. Do not minimize this; the brief that pretends otherwise loses credibility on everything else.
V. Proposed long-distance plan (as a signable schedule).
- Summer: father, 8 consecutive weeks beginning the Saturday after the last day of school.
- Winter break: alternating, father in odd years, December 26 through January 2.
- Spring break: father every year, in Durham or Seattle at his election.
- Thanksgiving: father in even years, Wednesday through Sunday.
- Four long weekends per year in Durham, father's election on 30 days' notice.
- Travel: mother books and pays 100% of the twins' airfare on nonstop RDU-SEA service; twins fly as unaccompanied minors until age 12 under the carrier's policy [UNVERIFIED - confirm current age threshold and fee]; father pays his own travel for Durham visits.
- Video contact: Tuesday, Thursday, Sunday, 7:00 p.m. Eastern / 4:00 p.m. Pacific.
- Makeup time: any block missed for the child's illness makes up within 60 days at the receiving parent's election.
Not supported yet. That the Durham schools are better than Bryant Elementary. I have no comparison data. That maternal family in Durham will provide childcare: no declaration from the sister. That the twins want to move: do not raise this without knowing whether the court will interview them.
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Assumptions I made. That Washington's relocation statute governs and applies a presumption favoring relocation [verify - this is the single most consequential assumption in the outline]. That the 2023 plan is operative and unmodified [verify]. That notice was properly served on 3/2/26 [verify - I have not seen the notice itself].
Where this is weakest. Factor IV. The exchange log cuts against us, and the brief currently handles it with a concession and nothing else. It needs the affirmative fact about who runs the twins' medical and school life, sourced to records, in the same paragraph. Second weakest: the school-quality argument, which is currently an assertion with no data behind it. Cut it or fund the research.
What only you can decide. Whether Ms. Kalra offers to stay if the court denies the move. Offering reads as good faith and reassures a judge who is looking for a reason to say no, but it also tells the court the move is optional and the $56,600 salary difference is not a real need. Taking the position that she is going either way forces the court to choose between two custodial outcomes, which sometimes wins, and sometimes gets read as leverage against the children. Also yours: whether she funds all of the twins' airfare. At roughly $2,400 per round trip for two children, four trips a year is $9,600 she does not have, but travel cost is the most common stated reason these requests are denied.
What would make this materially better. (1) The current text of RCW 26.09.405-.560 with the factor list, which would let me replace the [UNVERIFIED] framing with the real one. (2) Airfare quotes for the proposed blocks. (3) A declaration from the sister in Durham on childcare. (4) Whether Judge Amini has ruled on relocation with school-age children in the last two years.
Why this prompt is built the way it is
## Framework
1. **Name the test before you argue it.** Relocation is usually its own statute or leading case, not the ordinary best-interest analysis. Identify it, state who carries the burden, and mark the whole framing for verification.
2. **Procedure before merits.** Notice content, timing, and the objection window decide cases outright. Frame these as items to confirm against the current statute, never as a remembered deadline.
3. **Posture drives structure.** The relocating parent leads with good faith and the plan. The objecting parent leads with the relationship that exists now and the alternative that solves the mover's problem without the move.
4. **One factor, one fact, one source.** Every factor gets a specific fact and where it comes from. Factors with nothing behind them go on a separate list, not into the brief.
5. **The plan is the case.** Blocks, travel, who pays, who flies with the child, virtual contact, makeup time, both school calendars. Vagueness here is the most common reason relocation is denied.
6. **Answer good faith with facts.** The offer letter, the salary, the housing, the school, the family at the destination, and the one fact that makes the move look like it is about the other parent.
7. **Answer the question from the bench.** What happens if the court says no.