In the case of Kotara v. Kotara, the Virginia Court of Appeals, in an unpublished decision, ruled that it could not enterain an ex-husband's appeal of a circuit court decision denying his motion to transfer spousal support matters from Virginia to Texas. Husband moved to transfer jurisdiction from Virginia to Texas on the basis of the forum non conveniens doctrine. The Virginia court denied the motion. Ex-husband appealed. The Virginia Court declined to hear ex-husband's appeal because he rmoved to transfer a non-existant case. Before moving to transfer jurisdiction, ex-husband should have moved to modify support, which was what he was trying accomplish in Texas. Therefore, the order was not a final order or an interlocutory order and could not be appealed to the Virginia Court of Appeals.
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