Then he can go straight to court and start the process with the certificate.
You have to file the application and the orders you would seek are both interim and final. The interim orders would be immediate contact and how often you want it.
Final orders would be what you want to be the ongoing contact and residency of the child.
The affidavit would show how he has a good relationship with the children and what role he plays own their life.
How she has cut off contact etc.
The court will not look positively on her refusing to allow the children to see the father. He should set out how often he calls and if he has phone records to show the calls he should attach them.
He should not harass her but simply proceed too court.
I hope this makes sense and is of assistance if there is nothing further
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