2011cp_trl.pdf (last visited Feb. 8, 2013) (website of die Hague Conference on Private International Law); see also Appellee's Br. at ADD-30 (providing another translation of art. 336). 18 .Article 169 provides, in relevant part: “When a divorce or separation case is filed, the judge shall take sua sponte temporary measures necessary for the duration of the lawsuit particularly those concerning ... the care and protection of the children.” Appel-lee’s Br. at ADD-30. 19 . By "sole custody rights to the Mother,” we mean that the Father would, at least for the time being, not retain any "rights of custody” (as understood under the Hague Convention) — including a so-called “ne exeat " right to block the Mother from removing the children from Turkey, see Abbott, 130 S.Ct. at 1987 (<HOLDING>) — and therefore no "rights of custody” of the
holding that an indigent party has the right to courtappointed counsel in a private child custody proceeding in which the other parent is represented by counsel provided by a public agency holding that a parent has a right of custody by reason of that parents ne exeat right the authority to consent before the other parent may take the child to another country recognizing duty of parent to control conduct of child holding that the domicile of the child follows that of the parent with lawful custody holding that the right to support is not subject to waiver by either parent