Ad Litem Interogatories help

[ArkStepMom]

We (NCP) have had our first Ad Litem meeting  and have been furnished with her Interogartories- 12 questions in all and we are having some difficulty keeping answers "succinctly" formatted!! The last 2 questions ask "...state succinctly the reasons you feel you are the best parent to have custody..." and "...states succinctly the reasons you feel the opposing party is not the best person to have custody..."

at issue for NCP are 1) Child's 5 years of recurrence of excessive bug bites gone unresolved and supported by Dr visits and prescriptions
                 2) Child's teachers' request for child to be seen by Dr-> the subsequent referal to Child Psych. and the abscence of follow up
                 3) Child handcuffed to bed to prevent her from scratching at bites
                 4) Child's 4 school moves from K through grade 2
                 5) CP's Numerous residences with child since 1998 divorce with an undetermined number of male companions whom she was not married to
                 6) Fights both physical and verbal witnessed by child between CP's current spouse, spouses ex, and various unknown persons
                 7) Frustration of visitation with tardiness and visitation denials
                 8) Child's living conditions-3 bdrm home for family of 6 with child sharing one bedroom with two other children and childs concerns of having nothing of her own ex: clothes, space, bed
                 9) Child(8) being furnished with intimate knowledge of court order and stips and governing herself while away from CP's home

of the issues for CP most are unknown but it is presumed that 2 contempts, both occuring in 2 seperate summers involving child being taken out of state for vacation during CP's visitation and we expect Cp will bring issue with lack of telephone contact with child on NCP's parenting time which there is no stip in order for ( NCP's itemized tele. bills can prove otherwise)

Q1) With all NCP's concerns how should they be summarized without making NCP sound like he's anti-CP to the Ad Litem?

Q2) Aside from "NCP provides child with Happy, Healthy, Stable and Nurturing home" is there anything else that should be adressed in why NCP should have custody?

[socrateaser]

>We (NCP) have had our first Ad Litem meeting  and have been
>furnished with her Interogartories- 12 questions in all and we
>are having some difficulty keeping answers "succinctly"
>formatted!! The last 2 questions ask "...state succinctly the
>reasons you feel you are the best parent to have custody..."
>and "...states succinctly the reasons you feel the opposing
>party is not the best person to have custody..."
>
>at issue for NCP are

>                 1) Child's 5 years of recurrence of
>excessive bug bites gone unresolved and supported by Dr visits
>and prescriptions
>                 2) Child's teachers' request for child to be
>seen by Dr-> the subsequent referal to Child Psych. and the
>abscence of follow up
>                 3) Child handcuffed to bed to prevent her
>from scratching at bites
>                 4) Child's 4 school moves from K through
>grade 2
>                 5) CP's Numerous residences with child since
>1998 divorce with an undetermined number of male companions
>whom she was not married to
>                 6) Fights both physical and verbal witnessed
>by child between CP's current spouse, spouses ex, and various
>unknown persons
>                 7) Frustration of visitation with tardiness
>and visitation denials
>                 8) Child's living conditions-3 bdrm home for
>family of 6 with child sharing one bedroom with two other
>children and childs concerns of having nothing of her own ex:
>clothes, space, bed
>                 9) Child(8) being furnished with intimate
>knowledge of court order and stips and governing herself while
>away from CP's home
>
>of the issues for CP most are unknown but it is presumed that
>2 contempts, both occuring in 2 seperate summers involving
>child being taken out of state for vacation during CP's
>visitation and we expect Cp will bring issue with lack of
>telephone contact with child on NCP's parenting time which
>there is no stip in order for ( NCP's itemized tele. bills can
>prove otherwise)
>
>Q1) With all NCP's concerns how should they be summarized
>without making NCP sound like he's anti-CP to the Ad Litem?

Best way is to simply concentrate on why you would be the better parent, and not what's wrong with the other parent. If you can pull this off, the GAL will probably drop dead of a heart attack, because he/she's used to reading a boatload of anger from both sides.
>
>Q2) Aside from "NCP provides child with Happy, Healthy, Stable
>and Nurturing home" is there anything else that should be
>adressed in why NCP should have custody?

You tell me. Why do you think that you should have primary custody, irrespective of what the other parent may or may not do or say?