What to give the Evaluator?

[HeavenSent]

DH is going to court for chg of custody and contempt.  We are trying too figure out what to give to our evaluator.  This is what we have to offer that I think is relevent:

1)  Deposition of BM by our attorney--contains provable lies, including not co-operating with court ordered counselors, admits to allowing 14yr old's BF to sleep over, admits to 4 moves in 4years (4 different school districts), etc.

2)  Letters written by BM to 9yo child containing serious PAS scenarios (serious enough to make the physchologist furious!)

3)  Chronological list of all of BM's visitaion denials, interferences, etc. for past 4 yrs

4)  Phone records for past 3 years showing over 100 attempted contacts with no response

5)  DH's personal calender of notes containing all details of conversations / confrontations with child, BM, SF, shrinks, etc.

6)  Nasty letters from BM to DH saying don't come to school functions, church plays, field trips, etc.

7)  BM was charged with disorderly conduct and put on 6 mo no contact due to scene she made at child's church program

I have read through a lot of posts here about this topic.  The general consensus seeems to be not to bash the other parent and not give too much ifo.  OK.  

I'm getting pretty overwhelmed!  I don't know how to sort through the plethera of information I have.  To me, it is all relevent, and it is all bashing the BM (rightfully so in my opinion).  I've got to get it together, and quick-like.  Any advice or suggestion would be very helpful.

thank you.

A little background if it makes any difference:  First time BM took us to court 5 yrs ago to change custody from DH to BM, GAL recommended that son stay with Father, judge ruled against that, and changed custody to crazy BM.  This time, when DH filed, same judge specifically asked that the same GAL be used.  The GAL told us that our case was the ONLY time that the judge had ever went against her recommendation.  And that she is still of the same opinion that child should be with Father.  GAL and judge hand-picked the evaluator, who seemed very favorable to DH at our meetings so far.  

I say this because I have read a lot of posts here about GAL's and evaluators telling you what you want to hear to get things out of you.  That never crossed my mind before, so now I'm a bit more sceptical of the evaluator.  However, I do know the GAL is on our side, because of the previous recommendations she made to the court.  And because the GAL requested to be at BM's deposition.  GAL had really went through the information we had given her and done her homework; she nailed BM on quite a few issues.

[CustodyIQ]

Hi,

It's true that you should not bash the other parent for the sake of bashing.

All "bashing" should be provided in the context of threat to the child's welfare.

All seven of the things you listed could be presented in such context.  I think all of them are relevant to provide an evaluator.  I don't think any of them could hurt you.  Worst thing that happens is likely that evaluator may not find some of the things relevant.

It all will amount to mountains of documents, likely.  It would be helpful if you can outline the significant portions (e.g., which pages and lines in the deposition transcript show XYZ).

GAL would have much explaining to do to change her recommendation, so you're probably right about her perspective.

However, you should maintain a healthy skepticism for the evaluator's perspective.  That way, both you and DH will always watch your Ps and Qs around the evaluator, will be thorough in the evidence you provide, and won't presume that any slip won't be held against you.