You didn't give much information regarding your specific circumstances (i.e., where the child is going and why), so it's difficult to tell you what to include in your motion papers.
First thing though is, unless you have extraordinary circumstances (i.e. attending a funeral, etc.), I don't see how international travel qualifies as an emergency issue for an Order to Show Cause application. This should probably be included in a regular Motion.
In general, I would suggest including in your Certification the following:
(a) complete travel itinerary, including flight info, destination, name/address/telephone number of where the child would be staying as well as names of people in traveling party;
(b) reasons for the travel/trip and why client believe it is in the child's best interests;
(c) documentation regarding your client's attempts to obtain the other party's consent;
(d) documentation/information supporting the safety of the planned trip/travel destination.
Additional information would likely be needed based upon the other party's reasons fro refusing to consent to the travel.
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Blake Rush Esq.
Easton PA
(610)258-4003
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Original Message:
Sent: 04-27-2015 15:15
From: Alexandra Conti
Subject: OSC:Parent is unreasonably withholding permission to allow child to fly abroad
Does anyone have any guidance (or sample pleading) on what a court is looking for in a certification for an Order to Show Cause when one parent is unreasonably withholding consent to allow the minor child to fly out of the country with the other parent. Thank you.
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Alexandra Conti Esq.
Union NJ
(908)810-8588
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