Gag Order / PAS / Help writing motion

[mudbunnies]

okay. this might be a bit long winded, i'll try to keep it short.

history.  parents lived together first year of child's life, mom took off, dad tried for 2 years to get visit, dad files paternity action, dad gets visits as of spring, 2002, since spring'02 dad has only missed 2 weekends, however mom has denied about 5 other visits, including summer '03, child has made continual comments that dad has diligently worked around, kept positive attitude, etc.

child arrives at dad's on friday nite, 9ish, goes to bed, gets up in morning and says "okay i spent the night now i have to go home" dad & step-mom work around that without dishing CP, then child starts up with "when i'm old enough mom's taking me to talk to the judge so that i dont have to come visit u"

child is currently 5 1/2 years old.

CP mom has continually informed child of "today i'm going to court" "the judge was mean to mommy" kind of comments, dad has repetitivly instructed mom to not discuss court with child... etc... etc..

dad has previously filed for contempt re clause in FJ forbidding discussions such as these with child, nothing done todate as her atty has stalled hearings

dad now wants to file for a specific gag order wherein if violated dad gets custody and to file for counseling of CP for Malicious Mother Syndrome and PAS, evals, whatever,

we're trying to prepare this motion and this is a new one on us,

any wording suggestions? any advice? how have any of you proven or defended on a claim of PAS? any of you gone the gag order route?

once i have some meat to the motion i will post it for review

i'm short on time for this one and am trying to get it done by monday afternoon and filed as an emergency issue

thanks for listening and thanks for any posts.