In In re Marriage of Condon (1998) 62 Cal.App.4th 533, a mother sought to return to her native Australia with her two children after dissolution and child custody proceedings were decided in the California family courts, where the family had resided for several years. (Condon, supra, 62 Cal.App.4th at pp. 536-541.) The parents had been temporarily awarded joint legal and physical custody of the children. (Id. at pp. 538, 550.) The trial court concluded that while each parent was fit and " 'it would be in the children's best interest to spend significant periods of unmonitored time with each parent ... it was also in their best interest that the mother be allowed to reestablish her residence in Australia.' " (Id. at pp. 539-540.) Accordingly, the custody order provided that the children were to spend the school year with their mother in Australia, and spend their four school vacation periods with their father in California. (Id. at p. 540.) The children's father appealed. (Id. at p. 541.) The Condon court also stated: "Finally, before permitting any relocation which purports to maintain custody and visitation rights in the nonmoving parent, the trial court should take steps to insure its orders to that effect will remain enforceable throughout the minority of the affected children. Unless the law of the country where the children are to move guarantees enforceability of custody and visitation orders issued by American courts, and there may be no such country, the court will be required to use its ingenuity to ensure the moving parent adheres to its orders and does not seek to invalidate or modify them in a foreign court." (Condon, supra, 62 Cal.App.4th at pp. 547-548.) In Condon, the reviewing court refused to interfere with the trial court's order allowing the relocation, concluding that "the careful balance the trial court struck ... could be reasonably found to serve the best interests of the Condon children." (Condon, supra, 62 Cal.App.4th at p. 554.) However, the court noted: "The delicate balance the trial court struck depends on the mother placing her two boys on flights to Los Angeles four times a year and resisting the temptation to move away once again ... . Meantime the mother once before defied the order of a California court by secretly transporting her children to Australia and keeping them there without allowing their father any access until the Australian courts ordered their return under mandatory provisions of the Hague Convention ... ." (Ibid.) The children's father presented authority showing that enforcement of the family court's orders in Australia could be problematic, but that registration of the California order with the Australian courts would provide some measure of protection. (Id. at pp. 541, fn. 9, 556-557, 559-560.) The court also observed that "the Hague Convention protects a custodial parent from unlawful removal or retention of minor children for only one year" and that "the court of the requested state ... is not bound to order the return of the child if the person opposing its return establishes the parent requesting return 'was not actually exercising the custody rights at the time of the removal or retention, or had consented to or subsequently acquiesced in the removal or retention' or 'there is a grave risk that his or her return would expose the child to physical or psychological harm or otherwise place the child in an intolerable situation.'" (Id. at p. 556 & fn. 22.) Because "it was possible, although not probable, an Australian court with less stake in the children's relationship with a California father would consider it against the best interests of those children to require them to travel eight thousand miles ... four times a year," the court concluded that "a custody order which is guaranteed enforceability for only 1 year of the remaining 10 to 12 years of minority represents an abuse of discretion by the issuing court." (Condon, supra, 62 Cal.App.4th at p. 561.) The court noted: "Such an order does not adequately protect the interests of this state's citizen, the father, in maintaining a relationship with his children, nor does it adequately preserve the policies this state's Legislature has declared should govern child custody arrangements." (Ibid.) After concluding the order would not have guaranteed enforceability in the Australian courts, the court remanded to the trial court to obtain the mother's concession of continuing jurisdiction in the California courts and to create sanctions calculated to enforce that concession. (Id. at pp. 535, 562.) The trial court was instructed to create sanctions, which "should include the posting of an adequate monetary bond within the mother's means and the potential forfeiture of all or some support payments upon proof the mother is disregarding essential terms of the court order or has violated the concession of jurisdiction by pursuing modification of the California order in the courts of Australia or any other nation." (Id. at p. 562.)