Undertakings that will protect the child from grave risk for only a very limited time are insufficient to defeat an Article 13(b) claim. See Walsh, 221 F.3d at 218 (“The Convention does not require that the risk be ‘immediate’; only that it be grave.”) The determination of whether any valid undertakings can be crafted in such a situation is inherently fact-bound. See, e.g., Turner v. Frowein, 253 Conn. 312, 752 A.2d 955 (Conn.2000) (remanding for further consideration of alternative care arrangements and legal safeguards for repatriation of child, where evidence established that father sexually abused child and physically abused mother, home country authorities had failed to respond to mother’s complaints, and home country had no mechanism for a no contact order); Walsh, 221 F.3d 204 (<HOLDING>). However, the terms of the Convention, as well
holding that a child was not barred by a former statute of limitations applicable to actions to establish the existence of a father and child relationship when the current action was to establish the nonexistence of a father and child relationship and the presumed father no longer persisted in maintaining paternity holding district courts order with undertakings would not sufficiently protect child from violent father who abused mother and regularly ignored court orders holding that evidence was sufficient to support trial courts best interest finding where mother allowed child to be in contact with individual who had physically abused her mother was not capable of caring for child on her own mother admitted at trial she had not found stable employment and child was doing well in her current placement holding evidence insufficient to terminate mothers parental rights under section c because mother made arrangements for adequate support of children evidence showed mother left children with father who maintained steady employment and adequately supported children mother knew that father would provide adequate support and mother left children pursuant to agreed divorce decree holding that court could permit grandparent or other person having substantial past contact with child to intervene in pending sapcr even though original suit requesting possessory conservatorship could not be filed by grandparent or other person and further holding that stepgrandmother had standing to intervene to seek managing conservatorship of child under section 102004b and section 1020039 where natural mother abandoned child after birth parents were divorced natural father remarried father had custody of child after father died child lived first with stepmother then with stepgrandmother and mother first sought custody when child was eleven years old