in this type of case, you can say that the parent is alienating the child against you and here is what she is doing: and then list examples of things she has done and said to the child, in front of the child, and the times she has said things in front of you AND in front of the child. You should include much of what you wrote here. What you wrote in your question is excellent and is good language for what to put in court papers. You will want to say the following:
Bring up the times she has said things, what she has said and that she said it in front of the child
Bring up the times she has said things in front of you and the child, which makes you a witness
List the mother's refusal to keep you involved in the child's life, such as keeping you away from the child's teachers.
List her decision to take away overnights and don't say she wants more money -- say that she is taking away overnights to keep you away from your daughter. You have to make a case for parental alienation, not for child support, etc. so you'll be listing things that have to do with her keeping the child away from you.
List how she uses the child against you
Include that she says if you don't do XYZ, you can't see the child and therefore she uses the child as a pawn
Do you have proof of her mental instability? You don't want to allege that if you don't have proof. Make sure before you state that, that you have proof of this. You can't just state it without backing it up, so make sure to list any bizarre behavior she has shown.
Refusing mediation is not necessarily part of PAS but you can put it in there at the end if you want, although that is a separate issue.
HOw has she taken the child away from you -- you indicate that above, so explain that.
Also, you use perfect language by saying the mother is putting her own needs above the child's --- you can use that language and also state that the mother is not looking out for the child's best interests. (The court understands that phrase very well in every state in the nation). State that as a result of all of the above, the child is being negatively affected and you are concerned for her safety, her well-being, and her mental and emotional health by being a pawn in the mother's war against you.