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#2

You would need to file an initial action for determination of custody. I would specifically add a motion to prevent removal of the minor children from the state depending on your ex-wife’s timeframe in moving.

Courts are generally reluctant to allow parents to move with the minor children, especially when you have a 50/50 schedule in place. You should go back through your records and be prepared to document that you have had 50/50 overnight time with your children as well as all of your involvement and payment of the children’s expenses as evidence of your relationship with the children in the event you do end up having to go to court.