Thank you once again for Accepting my Answer, your kind words in Feedback and your generous Bonus, I appreciate it, but again I will say that what I appreciate the most is the confidence you have in me by allowing me to help you with your questions and concerns,
Learning how to use the epi pen, first aid, CPR, these are all so important. We hope we'll never need it, but we should know these procedures (I am so embarrassed to say that I faint when I see blood and cry when I see someone in pain, so I never learned any of these procedures. Although I suppose if one was compelled to learn them, I probably would, but I would graduate at the bottom of my class.
When you get to the hearing stage, as I said before, speak softly, and respectfully, XXXXX XXXXX assertiveness so that the Judge knows that you know what you're talking about. Remember to say everything that is in your Counterclaim (most of the time, Judges have not read the pleadings), keep stressing the "best interests of the child", let the Judge know what the father was not willing to do, like this
"Your Honor, I've heard so much about children suffering and dying needlessly and how if someone had known CPR, the child could have been saved, so I decided I had to enroll in a course to learn it and suggested to Mr. ____________ to learn it also for the benefit of our son, but he couldn't be bothered. I asked Mr. ______________ to ____________ , but again he found an excuse to avoid it. I don't know how to make him care for his son so I've given up.
Just keep saying that for everything he has refused to do, but don't do it in an accusatory tone, Use more of a plaintive tone, so the Judge gets the picture. You should also make sure you get the Judge to see what a poor and negative example he is setting for your son. Just keep thinking that if he gets the Judge to feel sorry for him and rule in his favor, your son will not be taken to pre-school any more, he will be lied to, and he will be made to feel very insecure. And, don't forget to drop it here and there that he refuses to work which not only sets a bad example for your son, but also deprives him of child support.
It would help, if you wrote down some notes of what you want to say, that way, you won't forget anything. But, the most important thing that you must say and you should write this in your notes several times -
"Petitioner's Petition MUST be dismissed because there have been no change in circumstances, substantial, or otherwise which would warrant Petitioner filing his Petition to Modify Custody and, therefore, according to law, it must be dismissed".
Let me now when you are filing your Answer and Counterclaim and what, if anything, you have changed.
Stay well and Kindest Regards,