Depositions and trial date set - suggestions?

[maxwell]

We got back from another hearing and the Judge set our trial date for early July. Currently I have sole custody of my 15-month old son as BM has not cooperated with the court at all.  She has supervised visitation and has not made any attempt to see him (though lies and says I do not return her calls to my cell and that she lost my home number which is publicly listed) for over 2 months now. We also filed a Rule to Show Cause (4 contempt charges) that we agreed will be heard the day of the trial (which is not good news for her).  The GAL is 100% behind me and cannot evaluate her as she has refused to let him or pay him the $2k she owes (her half). It appears she wants to go through with this -- so that she can be 'viewed' as a victim rather then 'give up' her son to me in a settlement (so she implied to my attorney). I am hoping she wants to settle as I am willing to forgo her child support (which she has failed to pay) -- this may be help as she apparently uses her children as an easy way to get money.

Anyway, it been a long process and I am anxious to get this over with and not worry as much anymore. We were going to wait it out but there appears no need to.  But I do worry that the Judge may give her unsupervised visitation as I hear they don't like to leave cases with supervised -- maybe he will leave it given she meets certain conditions (like the Psych exam she was ordered to take also).  She is definitely a borderline and narcistic. (She was raised by her grandparents as her parents were druggies and she may have been sexually molested as she as much admitted to me once but this does not excuse her behavior.) She just cannot take care of children and even admitted to the other Judge that she didn't care for my son properly the last time he had an ear infection.

BM is a deceiver of men -- this is her MO -- she is 30, married/divorced 3 times, 3 kids by different fathers, and 3rd custody battle (first child she abandoned and didn't have for ~9 years).  She has a criminal record and recently committed ID theft of my credit card.  Obviously she is deceiving this latest b/f which he may find out by our questions. The GAL also suspects drug use although she passed 2 tests (though the Doc noted her hair was chemically altered and she was ~2 months late for one of them).

We are deposing her and her boyfriend soon and I want to get my attorney some questions to ask both. I think I know mostly what we want to ask but wanted to get any suggestions here also.  

I am a little nervous about the final hearing that my attorney says should take only ~1/2 day. It has been a surreal experience --- one that I could never have imagined. My son is the light of my life however and I think has weathered this wonderfully. I just pray the outcomes continue to be in his best interest.

Thx