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In Meredith v. Meredith, 759 F. Supp. 1432 (D. Ariz. 1991), the
Father, an Arizona resident, was not ordered to return his daughter to
her mother under where the father, who had legal custody, took the
daughter from France, where the mother was hiding her after requesting
that her daughter visit her parents there. The daughter was not a
"habitual resident" of France, and thus the protections of Hague
Convention are not triggered. To equate the temporary removal and
subsequent sequestration of the child to habitual residence in France,
would be to reward the mother for her ability to conceal the child.
Concealment does not cause the place of concealment to become the place
of habitual residence.
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