“In these motions, the parties both seek to vary an existing interim custody and access order made pursuant to section 16(2) of the Divorce Act. The legislation does not set out a specific test for variation of interim custody and access orders. Although section 17 (1)(a) of the Act authorizes the court to vary a custody order, and section 17(5) enumerates the factors that the court must consider in doing so, that section only applies to final custody and access orders (Brooks v. Brooks, 1998 CarswellOnt 3097 (C.A.); Lagrandeur v. Lagrandeur, 2017 ONSC 6967 (S.C.J.), at para. 41). However, the court does have the jurisdiction to change interim custody orders made under section 16(2) of the Divorce Act in appropriate circumstances. The Ontario Court of Appeal has held that typically, interim custody and access orders should not be changed unless there is a “manifest change in circumstances or any important new evidence to justify a change in the status quo” (Serruys v. Serruys, 1982 CarswellOnt 305 (C.A.), at para. 12). It has emphasized the importance of minimizing interlocutory proceedings in custody and access matters, stating that any decision can generally be only “guess based” without the benefit of a full hearing with viva voce evidence and cross examination (Serruys, at para. 12). Accordingly, there should be sound reasons that militate in favour of taking immediate action with respect to the parenting arrangements rather than waiting for a final hearing on the issues (see also F.(H.) v. G.(D.), 2006 NBCA 36 (C.A.), at para. 17).”