1. Love
Talk about how you show affection to your child/children, and, if suitable, how other parent does so (or does not)
2. Food preparation and types of food prepared
What are their favorite foods? What do they like? What do they hate? When do they eat? How often do they eat fast food vs food at home? If your spouse fills them with junk food, talk about that.
You should be able to talk about when they get up and go to bed and any inherent difficulties, their involvement in activities outside the home, chores and hygiene routines, etc.
4. Education
What schools have they attended? What are their grades? Show report cards and talk about difficulties they are having, teacher conferences, open houses, etc.
5. Time spent with child or children
In what activities do engage with the children, e.g., reading, park, zoo, TV, etc.
6. Medical care
Who provides insurance for the child? Who are their doctors? Do they have their immunizations? Any particular health issues the child has? If child is on medication, does the other parent ensure child takes it regularly and on time?
7. Dental care
Who is their dentist? Who takes them to appointments? Also discuss records, current state of teeth, future work anticipated (e.g. braces)
8. Religious training
Do the children attend church? Where? How often? Who is their pastor, priest or rabbi? Who takes them to church? Are both parents same religion? Any obstacles to continuing the children in their faith?
9. Communication
Do the children openly communicate with you and/or other parent? Any difficulties in this area?
10. Provisions for child care
Who will watch the children while you are gone? How often are you gone? What are your expenses for child care?
11. Housekeeping
12. Child’s temperament
13. Child’s preferences as to custody and why
14. Home condition and location – accessibility to parks, schools, churches, hospitals
15. Family in the area – grandparents, aunts, uncles, cousins, godparents
16. Physical description of family residence – rooms, yard, etc.
Remember, this is not just about bashing the other parent - it is about showing that you are an appropriate caregiver yourself. If your child or children have difficulties while in your custody, don't try to hide them from your attorney. Instead, be upfront about the problems so that you and your attorney are prepared to address them with the judge. After all, it is likely the judge will find out about the problems, and you don't want him or her to think that you are in denial about those issues.
