Permanent custody award REVERSED; absent express notice to parties, trial court ERRED in relying on evidence from temporary custody hearing in making its final custody determination; parties had no notice that trial court would consider testimony from temporary hearing and trial court relied on its memory and notes, because transcrIpt from temporary hearing was not filed.
Pace v. Pace, S10F0843 (10/04/10), 10 FCDR 3173
From: Fulton County Daily Report, 10/15/2010