The reason I was asking for the details of what she is asking for is to check to see if she is trying to exclude him from her road - or whether it is a simple "don't come near me " one.
The court would see an applictaion that limits his ability to go down a particular street as being of more significance than one which simple stops him from doing something he has no intention of doing anyway
I ask because the fact that he has taken drugs in the past is a possible problem in terms of dealing with the court.
However he will need to create a Statement in reply to the allegations in any event.
He should use her statement as a guide to how a Statement should be set out, and then deal with each allegation in turn.
His responses should be clear straightforward and factual - not emotional.
He shoudl get screen shots of any texts and attach them to his statement.
He will need to be honest about his drug use.
This is about showing that she has no fear of him - not about making allegations against her.
He will also need to write down what he wishes to say to the court - as opposed to what evidence he wants to give.
This shoudl be about saying that he does not feel that she needs an order because in fact he has never been a problem to her and he can only imagine it is part of the games she is playing with regard to the children and a ploy to obtain legal aid for the issues regarding the children
He can ask a friend or family member to ho into court with him acting as his MacKenzie Friend.
They can take notes and organise his paperwork - nothing else.
At court they will try and convince him to give his undertaking not to do these things - one step down from an Order - but he shoudl hold out and at least ask the Judge to read his statement before agreeing to anything
Please ask if you need further details