Thank you for your follow-up. That helps tremendously. Your son can go to the local family courthouse and file a motion for a 'change of venue' on the basis that since the parties all reside in PA, the jurisdiction has to be updated to Pennsylvania and not Florida. Then he can file a petition for modification of custody based on PA law and request that the courts re-evaluate the past conditions and update the order. Please know that your son would have to serve the ex and she could contest either or both of these requests before the court. Such requests are typically granted when there is no longer any residency attachment to the past state, and since all of the parties and the child reside locally, the local courts have a more direct interest in the outcome. I doubt that he can get daycare refunded but he can request an amendment going forward based on this modification of custody and child support, which could then remove that past fee if it is no longer relevant in this instance.
Hope that helps!
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