Possible to get temp order of custody?

[metamorphosis]

My husband has wed nights and eow visitation with his 2 sons.  At the beginning of summer visitation BM informed him that she was moving to Little Rock. (we are in arkansas as well, but more than 3 hours away from LR)  During the 6 weeks the boys were with us she did not work, moved out of her studio apartment and in with her aunt (in a 1 bedroom duplex)  This last time we picked up the boys she informed us that she has talked to her attorney and is in the process of filing paperwork to move the boys to New York.  (btw we provide all the transportation on visitation- 1 hour each way- even though she is ordered to do half because she does not have transportation.)  
When they had first split up in 2000 she kept the boys from seeing him for 4 months even though they already had a visitation order in place from the oldest child.  
Is there any way to get a temp custody order based on the fear that she might do this again only in New York?  
Also, would it be better for us to file for a reversal of custody before we are served with papers from her?  
Can you recommend a good lawyer in the Fort smith or Fayetteville area?  (jurisdiction is sebastian county, but if there is a better lawyer in fayetteville we will take it.)

We are hoping that since we are married (she is not)
My husband is gainfully employed (she is not) with the same company for 6 years
We just bought a house and technically she is without a permanent residence, the boys dont even have beds where they are at
and the fact that she has told the boys that they are moving to get away from my husband  
that we have a good chance of getting custody.
However, we have been told by an attorney that most of it is little stuff that is time consuming and hard to prove and that the judge os going to be looking for a straightforward "she sells drugs" type of case.  
We are also sure of the fact that if we file for custody she will say terrible things to the kids about their dad.  She already crosses that line, but we know it will get much worse which is mostly why we want the temp order.
What are our options and chances?

Thanks so much.

[socrateaser]

>>Is there any way to get a temp custody order based on the fear
>that she might do this again only in New York?  

No, but you may be able to reverse custody if you can show that the child has established roots, friends, family, etc., in AR, and that a move to N.Y. is not in the child's best interests, even though it may be in the mother's.

>Also, would it be better for us to file for a reversal of
>custody before we are served with papers from her?  

Well, if you know that she intends to move, then I would send her attorney a letter indicating your understanding, and stating that unless you receive written correspondence within 3 days stating that your understanding is incorrect, that you will file for a restraining order to have the court consider the child's interest in the matter.

>Can you recommend a good lawyer in the Fort smith or
>Fayetteville area?  (jurisdiction is sebastian county, but if
>there is a better lawyer in fayetteville we will take it.)

No, sorry.
>
>We are hoping that since we are married (she is not)
>My husband is gainfully employed (she is not) with the same
>company for 6 years
>We just bought a house and technically she is without a
>permanent residence, the boys dont even have beds where they
>are at
>and the fact that she has told the boys that they are moving
>to get away from my husband  
>that we have a good chance of getting custody.

None of the above is relevant. What matters iswhat has changed in the child's life, not what has changed in yours. The only relevant issue is that the mother is attempting to move the child into a location entirely foreign to the child, and that this will upset the status quo, in addition to frustrating the child's access to the you (rather than your access to the child, if you catch my drift).

>What are our options and chances?

I don't read tea leaves, and I don't have near enough facts to judge the quality of the child's life in her present environment. Be objective and ask yourself what does the child gain by moving to N.Y. vs. staying in AR? This is the question that the judge will be asking him/herself. If you can show, clearly and convincingly, that the child will benefit more by remaining in AR, then you win -- otherwise, you lose.