Hello again, Thomas, and thank you for the additional information.
Prior to the hearing, I would typically file a motion with the court requesting that the court order her to sit for a psychiatric examination, based on your personal knowledge of her behavior. It would be best if you had sworn statements from others who have witnessed her erratic and unstable behavior as well, in order to convince the court that such an evaluation is warranted under the circumstances.
If she is mentally ill, the evaluation should uncover that and would provide you with strong evidence to seek primary custody of your child and limit her visitation
, perhaps even having supervised visitation
only, depending on the finding of the professional.
Another option is to file a motion requesting that the court appoint a guardian ad litem (GAL) to assess the situation and make a recommendation to the court with regard to custody. This typically involves interviewing the parents and the child, and possibly others who may have contact with the child to determine which parent should have primary or sole custody
of the child. The GAL's report is often adopted by the court, so it can also constitute powerful evidence if it goes in your favor.
Here is a link that provides information on the role of a GAL:
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