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Change in Visitation Schedule Did Not Change Residence

A trial court that changed a 2-2-3 visitation schedule (two weekdays with one parent, two with the other, then alternate weekends) to the standard possession order by temporary orders in a modification proceeding did not abuse its discretion because it did not change “the designation of the person who has the exclusive right to designate the primary residence of the child,” Tex. Fam. Code § 156.006, when both parents remained joint managing conservators and retained the exclusive right to establish the child’s residence during their periods of possession. In re Bromberg, No. 03-13-00778-CV (Tex. App. – Austin Jan. 14, 2014) (orig. proceeding) (mem. op.).


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