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California Family Code Section 215

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After entry of a judgment of dissolution of marriage, nullity
of marriage, legal separation of the parties, or paternity, or after
a permanent order in any other proceeding in which there was at issue
the visitation, custody, or support of a child, no modification of
the judgment or order, and no subsequent order in the proceedings, is
valid unless any prior notice otherwise required to be given to a
party to the proceeding is served, in the same manner as the notice
is otherwise permitted by law to be served, upon the party.  For the
purposes of this section, service upon the attorney of record is not
sufficient.
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Last modified: January 12, 2009