Jun 6, 2003


Petitioner, Christopher , (representing himself) respectfully requests the court schedule an emergency telephonic conference with the parties regarding summer visitation for the reasons set forth in the attached Memorandum of Points and Authorities which is herein incorporated by this reference.
RESPECTFULLY SUBMITTED THIS 3RD DAY OF JUNE, 2003.
By:__________________________
Christopher ****** Petitioner

Memorandum of Points and Authorities
On April 18, 2002, this Court held a telephonic conference with the parties regarding the Respondent’s Motion to Continue the Evidentiary hearing in this matter. During that conference, the Court ordered that summer visitation would be as follows

The petitioner (Christopher A. *****)is scheduled to exercise his five (5) weeks of summer access beginning no later than one week after the end of the school year. The minute entry reads as follows “Mother and Father agree they will each have five consecutive weeks of parenting time with the children in the summer. Father will have the first five weeks and Mother will have the second five weeks. That five week period begins no later than one week following the end of school for the children” The respondent (Gigi *****) has not allowed the petitioner access to the children as set forth by this agreement. The first week of the petitioner’s summer visitation should have begun on May 30th at 5:30pm, however the respondent refused access to the children and has since written a letter stating that she will not allow access as prescribed in the Court order.
The Mother (respondent) has attempted to alienate the children from the Father and has refused access on several occasions in the past year, including; Father’s Birthday and children’s birthdays.

The mother has changed her phone number and has not allowed any communication with the minor children. The mother has previously had the children in day camps and has not notified the father as to the location of these camps nor has she provided any emergency phone numbers for contact with the children.
During previous summers there have been difficulties during the pick up of the children.

The respondent has attempted to block access to the children each year. For this reason it was agreed to simplify the summer agreement to have few exchanges for visitation each summer. The mother should be ordered to abide by the agreement that has been ordered by the court. Due to the continued violations of court orders by the respondent, the five (5) week period should not be broken into separate weeks. The Mother has attempted to alienate the father from the minor children and when summer visitation is separated into separate weeks she attempts to place fear in the children as to the summer camp or relatives that they may be with during that time. The children ages 8 and 10 are both boys and need the influence and support of their father. During the extended visitation the children have an opportunity to bond and enjoy summer activities. Over the course of the last 4 years the Mother has consistently disregarded visitation rights and telephonic access.
The Father should be allowed to begin his summer visitation schedule on June 13th at 5:30pm through Friday July 18th at 5:30pm.
The petitioner respects the Court and has made every effort to resolve this without contacting the Court. For several weeks prior to the end of the school year, the Father did not have a phone number for the Mother. She clearly is not acting in the best interests of the minor children.

Wherefore, it is respectfully requested by the petitioner that the Court schedule an emergency telephonic conference with the parties to address summer access concerns.

Respectfully submitted this 3rd day of June, 2003.








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