In Clum v. Seksinsky, 263 A.D.2d 507 (2nd Dep't, 1999), the custodial parent's actions did not constitute active interference or deliberate frustration where the custodial parent notified the non-custodial parent of relocation and allowed the non-custodial parent visitation and phone contact with the child. There, suspension of child support was unwarranted.