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I haven't offered more time; she has 8 weeks in the summer, Easter break, and every other Christmas break.  Since she doesn't pay child support, I think it would be reasonable to up her parental responsibilities, considering 300 miles isn't all that far.  I am sure she could afford bus fare for all of the school holidays.

I have sole physical custody and have had it since October 2009.  I have been in court at least once a year for this custody thing.  Is there any way to have an order to stop her from doing this?  It's a big waste of my time and the courts' time.

The court date isn't until 9/18; school starts on 8/12.  NCP knows that my daughter needs to be back 3 days before school starts.  I have school records, receipts from plane tickets, and health records.  When I answer the motion, do I request to dismiss based on no change in circumstances?

We are thinking about more visits during the school year; NCP lives 300 miles away and has been ordered by the court to pay travel costs.  Summer visits are too long; every summer my daughter gains weight and can't lose it during the school year.  I would like to shorten the summer visits and require shorter visits on school breaks. 

She's stating that she can better care for her needs; however, she has no job, no transportation, and is technically homeless.  Plus, she has 3 other kids.  According to the NCP, my daughter wants to go live with her; the only reason she wants custody is to collect child support so she doesn't have to work.  How do I get the case dismissed?

NCP is requesting a modification of custody, however there's been no change in circumstance that would warrant this.  I am writing the response under Points and Authorities, but need to pinpoint the section in the CA state code.
Thanks for any help!