5 Washington has not necessarily required cross-examination of the minor child in instances where a parent’s contact with a minor child could be restricted. See In re Dependency of H.W., 70 Wn. App. 552, 558, 854 P.2d 1100 (1993) (noting that due process was satisfied for the purpose of a temporary shelter care hearing where the accused parent had access to statements made by the children). Moreover, where the result of a hearing would only temporarily restrict a purportedly abusive parent’s access to a minor child, less process is due than in termination proceedings. See id. at 556-57 (considering the “obvious need for prompt and decisive action in order to protect a child from possible abuse and neglect’’); see also In re Parentage of Jannot, 149 Wn.2d 123, 126-27, 65 P.3d 664 (2003) (<HOLDING>). 6 [D]omestic violence is a problem of immense
holding that the clearly erroneous standard of review applies unless judgment is entered on the basis of documentary evidence alone holding that clearly erroneous standard of review governs district courts factual findings based on state record documentary evidence and inferences from other facts holding it improper to deny cat relief based on adverse credibility finding where objective documentary evidence establishes likelihood of torture holding that parties inability to agree on which private high school child would attend constituted substantial change in circumstances warranting modification of parenting plan recognizing that petitions to modify a parenting plan are initially evaluated based only on documentary evidence