Since you already have an attorney, you should direct this question to him/her. But for the most part, show causing a party for failing to comply with a current order of the court is a good strategy to use when asking a court to amend a current custody order.
You have indicated that you have a lawyer, and any question that you have should be directed to that lawyer.
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I agree with the answers of my distinguished colleagues. Retain local counsel to represent you in this matter. Good luck.
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