With no explanation, chose the best option from "A", "B", "C" or "D". of the children. [Ibid.] Absent exigent circumstances, changes in custody should not be ordered without a full plenary hearing. R. 5:8-6; Entress v. Entress, 376 N.J.Super. 125, 133, 869 A.2d 451 (App.Div.2005). That is so because, as we have noted in another context, even “a temporary decision to change custody can take on a life of its own, creating a new status quo.” Peregoy v. Peregoy, 358 N.J.Super. 179, 203, 817 A.2d 381 (App.Div.2003). The status quo ante is significant because “[a] party seeking to modify custody must demonstrate changed circumstances that affect the welfare of the child[ j.” Hand, supra, 391 N.J.Super. at 105, 917 A.2d 269; Beck v. Beck, 86 N.J. 480, 496 n. 8, 432 A.2d 63 (1981); see Todd v. Sheridan, 268 N.J.Super. 387, 398, 633 A.2d 1009 (App.Div.1993) (<HOLDING>). There exists, however, an equally weighty set

A: holding that a defendant must demonstrate that he would not have pled guilty but for the error
B: recognizing that the burden on summary judgment shifts to the nonmoving party once the moving party has met its initial responsibility of showing the absence of a triable issue of fact and that the moving party is entitled to summary judgment if the nonmoving party fails to make a sufficient showing on an essential element of the case
C: holding that a moving party must demonstrate changed circumstances which would have an impact on the childs welfare
D: holding party did not waive right to arbitrate despite moving to dismiss and moving for summary judgment on opponents claim
C.