I have posted several times about BF having a very "loose" custody order. He agreed to a custody order that leaves most things to be decided between the two parents. They have 50/50 joint custody.

There is nothing written up about vacations, holidays, doctors appointments, specific location of exchanges. The only thing that was written down is the time of drop off.

This arrangement does NOT work and never has. Bf claims to have agreed to this because after 2 years of countless mediations, psych evaluations, he is broke and (I think) he was intimidated by the BM. He just wanted to be done with it.

For months and years he has tolerated the most erratic behavior and PA from the BM. When I met him, I was dismayed at the amount of things she still had him do. He was already living separated from her. She was at work 24-7, while he took care of his daughter for 95% of the time, he would drop his daughter off at BM's house at 10pm and pick her up to take her to pre school every day. He did her laundry. I freaked out when I found out that he brought her laundry to our house. She would constantly call him. She demanded "inspections" to our house. Just to name a few things.

So, slowly he started understanding why i felt so upset. I explained to him that he needed to take care of himself and stop catering to the BM over and over. Things started changing. BM became more and more negligent with kid, angrier and angrier.

So, yesterday BF went back to lawyer and he is going to be doing a petition to appeal CO based on the grounds of BM violating the current order. BF has 30 days to appeal the CO, and he has until next Thursday. We have a slew of things on the list. She has been consistently late to pick ups, she pays a number of people to pick up and drop off her daughter on the days she has her (3days). She has used the excuse of dropping her off for having to stay late at work and not able to pick up the kid. But she is NOT taking the kid to school herself, even though she lives 2 blocks from school.

Also, she took skid to disneyland for 10 days. Skid came back completely bent out of shape and neurotic and said something really scary happened there.

Bf has emailed her withe the dates he would like to take skid to vacation, she did not respond and 3 weeks later the BM said she will not allow BF take skid for vacation. Two days ago she tried doing a last minute (24hrs) change in days. The lawyer said she is in violation with CO.

So it goes on and on....
In the petition BF is asking:

- Specific schedule including exact time
- Vacation, holidays, b-days divided up on the calendar, NOT OPEN TO INTERPRETATION
- Specific instructions about making doctors appointments
- Stating her difficulties keeping time and using her work schedule as an excuse (or lie)
- No badmouthing other parent in front of skid or drawing skid into custody related questions
- Specific mode of communication (emails only), calls only in medical emergencies (defined medical emergencies) and during vacation time. All communications must be in writing and replied to within 72 hours (unless medical emergency)

BF's lawyer is supposed to look through it on Monday, and BF will go and submit it.

I am really excited because I feel like BF finally understands the extent of needing specifics. He is finally understanding that there is no point of expecting the BM being reasonable. She has demonstrated over and over that she does not want to cooperate and her only goal is to punish BF for "abandoning" her. She actually said that to him.

So I am curious if any of you have suggestions, advice as to what to include in this petition? Thanks!