Sisti

I. INTRODUCTION

Erin Callahan (Mother) appeals the family court’s order adopting a family court services counselor’s recommendation to give Michael Sisti (Father) sole legal and physical custody1 of Mother and Father’s daughter (Daughter), with visitation to Mother. Mother contends the family court erred by denying Mother the right to cross-examine the counselor at an evidentiary hearing and by denying Mother’s request for a continuance to facilitate that cross-examination and to present expert testimony. On the appellate record before us, Mother — who is representing herself on appeal — has not met her burden as the appellant to show that the family court erred. Accordingly, we affirm the order.

II. FACTUAL AND PROCEDURAL BACKGROUND2

Mother and Father lived together from 2014 to 2020 and have one child together — Daughter, who is now 9 years old. In 2021, Father initiated this case by filing a petition against Mother for custody and support as to Daughter. The litigation has been contentious.

In its report, Family Court Services (FCS) recommends the court order that Daughter “primarily reside with father.” The Family Code recognizes only joint physical custody, where…