The respondent father brought an urgent triage request to schedule a motion prior to a case conference, seeking to limit contact between the applicant mother and their 12-year-old daughter.
The court considered the test for urgency under Rule 14(4.2) and recent jurisprudence regarding institutional delay as a potential tool of coercive control.
The court held that institutional delay alone, without evidence of manipulation by a controlling party, cannot justify waiving the case conference requirement.
The request for an urgent motion was dismissed, but the alternative request to schedule an urgent case conference was granted.