Endangerment or Neglect. If you are raising issues of endangerment you must relate specific incidents. Endangerment may be physical, emotional or developmental. A calendar may be helpful to document the dates of the incidents. Documentation can carry critical weight with this type of allegation. Documents may include:

• Medical reports documenting injuries from abuse or lack of supervision;

• Medical reports documenting complications because of neglect - health issues such as asthma from cigarettes smoke or lice from lack of hygiene;

• Police reports relating to police calls to the other parent’s home;

• Child protection reports;

• Counseling records for the child or the parent;

• Criminal or driving record of the other parent;

• Criminal or driving record of individuals that have significant contact with the minor child(ren);

• School records may document attendance problems, school performance problems, counseling issues or erratic child behavior while in the other parent’s care or after returning from the other parent’s care. REMEMBER: Endangerment only exists if you tie the other parent’s conduct into the child’s care and the child’s best interests. For example, if you allege the other parent has an alcohol problem. It only will be effective if you can relate specific incidents where the alcohol use or abuse affected the minor child(ren). (eg. The parent passed out on the couch while the child played unsupervised. The parent drove the child in the car while intoxicated. The parent was out partying consistently while the child was be cared for by a stranger.)

Parenting Plan. The custody evaluator will want to know what your proposal is for parenting. You should be prepared with research, facts and answers. You may wish to write out your answers to the following questions so that your response seems thought out. Do not over prepare, your response should not sound mechanical. The answers should include:

• Where will the child live? Why is that in the child’s best interests?

• What school will the child attend? Why is that in the child’s best interests?

• What will your work schedule be?

• Will that allow you sufficient time to supervise the child?

• What schedule do you propose for the other parents?

• How does that schedule provide stability?

• Why is that schedule in the child’s best interests?

(Remember: The custody evaluator is also looking at which parent is more likely to facilitate contact with the other parent. If you appear to be an unreasonable obstructionist with regard to the other parent’s contact, it may be used against you.)

PARENTING NOTEBOOKS. In a custody proceeding it is important to maintain a notebook including dates that events occur relating to the care of your child(ren). What is the daily routine? Who takes them to the doctor? Who takes them to school activities? List any concerns regarding the other party’s parenting including the method of discipline, drug use, alcohol use, disabilities or neglect.

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