I need a memo with the following fact pattern:

Mary Stanton, 34, married Chris Smith, 39 in April 2008. They had a daughter, Ava, born November 24, 2017. Chris is a NYC Transit Authority engineer who earns $62,00 a year (Including $12,000 in overtime). He lives in Bay Ridge, Brooklyn in a 1 bedroom rental. His mother is retired and helps him out often when Ava stays with him.

Mary rents a 2 bedroom apartment in Windsor Terrace, Brooklyn and is an Assistant Manager in the Brooklyn Target, earning $42,000 a year. Their daughter Ava attends a Charter School in Brooklyn and her grades are in the B+ range. She plays on the soccer team, takes karate lessons and has lots of friends in school.

The couple was divorced on May 3, 2019 in Kings Supreme Court. The stipulation of settlement provided the couple with joint legal custody; mom has primary physical custody and dad liberal visitation, which he exercises fully. Their agreement also prohibits Mary from relocating with Ava outside a 25-mile radius without Chris' permission or an order of the Supreme or Family Court.

Mary re-married two years ago to Bob Mathers (another Target Assistant Manager). Bob has been offered a "significant" (in wife's words) raise to manage a Target in Warwick, New York (60 miles from Brooklyn). Mary would also be able to transfer with no reduction in pay. The schools are reportedly very good in Warwick, according to Mary.

Mary brought a petition in Brooklyn Family Court for permission to relocate. We need to file opposition papers soon and I need a Memorandum of Law setting forth the law in this area to assist me in advising our potential client and drafting opposition.