Out-of-state non-custodial parent visiting with 3-year-old?

Have anyone had a court order a child under 4 y.o. to have taken out of state to visit the non-custodial parent? My lawyer told me that there is no chance that the court would order her to go see dad out od sate until she is 4. But I talked to a CFI and he he said he never heard of the 4 y.o. rule and he think the courts could order her to go out of state to visit dad. If you have similar experience in El Paso county courts, please share!