The burden in this application is on mother to show: 1. A change in the condition, means, needs or circumstances of the child and/or the ability of the parents to meet the needs of the child; 2. Which materially affects the child; and 3. Which was either not foreseen or could not have been reasonably contemplated by Shabbits J.: see Gordon v. Goertz, 1996 CanLII 191 (SCC), [1996] 2 S.C.R. 27.
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