Actually in these types of hearing, the judge will be asking questions with regards XXXXX XXXXX modification filing and contempt action. There really won't be an opportunity for opening statements, since the modification hearing is not a trial. But in terms of what to say, he should make sure he has specific dates and times with regards XXXXX XXXXX violation he will be citing. The more specific he can get, the more difficult it gets for the other parent to challenge that such events were fabricated by him.
Modification of custody is based on establishing that there is a change in circumstances which for the child's best interests should be modified. He should try to keep the focus on what is in the child's best interests and how the best interests have been placed in detriment because of mom's conduct and her violations.
So if he has not already done so, he should prepare an outline of the 29 violations, dates and times, what was ordered, how was it violated and how did it affect the child. Then he should outline how his relationship with his child is.
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