Spain, J.
In early 1996, plaintiff commenced an action for divorce against defendant and, shortly thereafter, the parties entered into an oral stipulation in full and final settlement of the issues of custody and visitation of their three children (born in 1989, 1990 and 1992). After confusion arose as to whether the stipulation precluded defendant from relocating the children to New York City, defendant secured new counsel and filed an answer and a counterclaim seeking...
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