Our counter-motion was filed with the court today. In our motion we are asking for modification of custody, child support, counseling for the mom, and a GAL. Based on our evidence and recommendation from the counselor.

BM filed her Motion and Motion to Compel with the Court back in January. Before the Counselor completed the therapy/counseling with SD. So the recommendation does not fit her motion. It actually shows just how far she went to lie in her motion and to her lawyer.

In the motion she filed it states (shortened version)
-DH never spends time with daughter, picks her up in NC drive to VA drops her off with family that she is scared of, and then takes her back to NC
-DH Always changes the pick up locations, times and dates
-DH does not pay enough child support and argues with mother in front of the child
- DH and new wife do not have a stable home and abuse the child
- Wants visitation and custody changed based on recommendation of the counselor.
- wants more child support and DH to pay her attorneys fees and is experiencing a financial hardship. (after making over $40k and $800 monthly CS living in Fayetteville, NC in a 2 bd aprt, car paid for, rent is $650.00)

The kicker is this even with all the evidence we have on her, years of emails, letters she signed banning him and his family from daycare and school - after joint custody awarded, wrong medications being sent, letter from doctor giving us correct information after mother lied, medication not coming for 6 weeks, no epipen coming with email stating she would not give it to him without him first paying her, lie about the allergist and test result, the lies on the counseling intake form etc (our books (evidence and medication log) is huge)

Our most detrimental piece of information for court is the recommendation and notes of the counseling sessions. On the intake form she wrote horrible lies:
- DH lies to the child - DH attempted to kill child in her sleep - SD has nightmares about us before and after visiting us - First wife abused SD in 2004 - 2005 - Second wife and SD (12 at the time) abuse SD - DH hit her during her pregnancy - stated DH was with her two years after they split - Stated the backgroud history for abuse is child support and child custody - stated that child hides clothing to keep from coming to visit father - and child stated she is afraid of father, stepmother and stepsister.

In the counselor notes and recommendation it states:
(After 9 sessions) Child states she feels warm and loved by everyone, DH, gr8tma, stepsister, a couple of my neices, her grandma, aunties, her counsins and her aunt Judy. Child states how she enjoyed putting up christmas tree and creating stocking with family, child states she love dad and mom, that she is not afraid of dad or mom, states she would like to stay with father for a longer time, and that her mommi told her to say dad was bad and gr8tma hit and beat her.

Counselor recommendations went as such: Child appears mentally confused by mom's brainwashing and why she would tell her gr8tma was mean and has not been, child appears to really love the time with dad and his family, child appears to be happy that she gets to visit with dad's family, child has no fears about the visits and that she (Counselor) had to continusouly tell the mother that there are no signs of abuse or transition anxiety. The counselor stated mother then stated to her " she doesn't like to make the drive to VA" for the exchange of the child for visits. (She doesn't mind you - we meet her halfway). The Counselor then recommended that since 10 January when the mother had child act out after taking her to the bathroom for an extended time - claiming child was afraid (mind you the counselor saw us with the child just before she and my husband went up stairs and the mother took the child out) that my husband get an Attorney and a Guardian Ad Litem be assigned because it needed to be determined exactly what the situation was since Mother's story was 180 degrees different from child and other side of the family with no evidence to back it up. Counselor also recommended visitation for father does not stop but should be increased.

So i am so interested and seeing what happens on 6 may in court. They wanted SD to be taken on the recommendation of the counselor - however the recommendation was in the father's favor.

Now the real kicker is this. We have to pick up SD next weekend for his visitation. She (BM) will have a copy of our motion before that time. I am anxious to see just how she acts. I fully expect her not to pick up the phone for DH's nightly calls, I think she will also not show up for the exchange the weekend before court. If not then she will really look bad in court and confirm again all that was put in the motion.