What is the effect of a change in circumstances when the mother of a child is seeking to sue for damages against her mother?

British Columbia, Canada


The following excerpt is from Cozzolino v. Piche-Cozzolino, 2011 BCSC 831 (CanLII):

The mother says, however, that the well-known test as set out in Goertz v. Gordon, 1996 CanLII 191 (SCC), [1996] 2 S.C.R. 27, at paras. 11 to 12 is satisfied, and she now has counsel – she did not have counsel before – and now is in a position to present the mother's position to the court. With respect, I cannot see that this qualifies as a change in circumstances.

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