Drafting Child Custody Exceptions

I need assistance with a mock case for law school. It is Family Law. A child custody situation. I will provide the details of the situation and i am hoping you can assist with drafting exceptions to the temporary order the Bias conferences officer drafted fully supporting the father, disregarding the concerns for the child's well being and disregarded everything the mother had to say. This will be a case located in Pennsylvania. Is that ok?

Hi Attorney A.I.....LET ME START BY SAYING ALL FOLLOWING INFORMATION IS SCRIPTED AND IS FOR MY MOCK COURT CASE FOR LAW SCHOOL. I am in Law School and this is a mock trial type case I need assistance with. OK I have attached the recently drafted temporary child custody order that an extremely unethical Conference Officer drafted and submitted to the court. He exhibited extreme bias against the mother in this cas, completely disregarding the childs best interests and not once taking into account the valid concerns the mother brought in her petition for Modification. Attorney A.I I would like your assistance in drafting the Child Custody Exceptions petition, clarifying and detailing with supportive legal evidence and strong legal precedence and standing. A.I, along with the exceptions, I would like your assistance with drafting the appropriate legal filing for the court detailing the instances the Conference officer acted by his own personal bias, never once thinking about the best interest of the child. In this Mock case, the Mother has full physical Custody of her 15 year old daughter and always has. The child has always lived with the mother and has always been financially supported by the mother and the child's step father even during her visitations to the Father's home. The mother provides any and everything the child may need while at her father's. This was to be a simple modification hearing to get into the current Custody Agreement an official Summer schedule due to the Father suddenly demanding the mother force the child to come to his home from Friday to Tuesday every other week and also Monday to Tuesday on the weeks in between. The mother drafted in her petition a clear outline of why it was not in the child's best interest for her to be subjected to such an extended stay at the Father's home. The mother presented valid concerns, explaining the absolutely detrimental effects to the child's mental and emotional well-being that the child would suffer should she be forced to accommodate the father's unrealistic and drastic forced visitation schedule change. 1st Unethical Act committed by The Conference officer: while interviewing the 15 year old child stated quote "I already made my decision with this case before you guys even got here, I just had to still meet with you all, so I promise this won't take long ". 2nd Unethical & Show of extreme bias: During the Conference the Conference Officer displayed no interest in discussing the valid concerns, in regards to the Childs well being that the Mother brought forth, while adding comments in support of each unsubstantiated excuse the Father claimed. 3rd Unethical Instance & Show of extreme bias: The Conference Officer stated to the child while interviewing her, "Your Mother thinks your Father should have to provide transportation for your visitation with him, but in this Court we like to actually do things fair", insinuating that the Mother was being unfair by asking the Court as well as the Childs Father to provide the transportation for the FATHERS VISITS WITH THE CHILD. 4th Instance of Extreme Bias by Conference officer:. Conference officer's summarization of the conference is the most solid proof of the bias claim being brought forth today. Conference officer writes a simple one line dismissive slight mentioning of the Mother's initial Modification Petition by stating : "The mother had a very lengthy filing which is on file......" that is his only instance of mentioning anything whatsoever in relation to the official petition that was filed in relation to this case. However, The Conference officer did write anothed page and a half speaking incorrect information and fully supporting the fathers request to bs accomodated. This Mock Trial and custody Conference setting is in PA. I need to know exactly what the legal Precedent is against this type of situation. Every issue the mother raised was *% completely unacknowledged. The Conference officer stood up for the father after every single dishonest statement he made. Please read over the attached copy of the Conference officers recommended temporary custody order and be sure to read the last * pages. You will see clearly that the Conference officer basically regards the mothers petition for modifications full of the serious detrimental concerns as " a lengthy petition on file". His only other remark in regards to the mother is when he stated the only issue the mother had was that the father is responsible for providing the transportation FOR HIS OWN VISITS WHICH WAS, YES, one big issue but FAR FROM THE ONLY ONE. The entire rest of the Officers summarization of the Conference is in full support of the father. In every instance. Including the fact that the mother has had to pay the Father over $* in gas in the last year to simply drive his daughter home from HIS OWN VISITS. He fully supported the father stating "ITS ONLY FAIR THAT the mother PAY FOR HIS TIME THAT DRIVING HIS DAUGHTER HOME FROM HIS OWN VISITS IS COSTING HIM. So in all I need assistance drafting a professional legal petition for Exceptions against this horrible custody order. Also for clarity. The current Custody Agreement that has been in affect for the past 8 years is that Mom has full physical Custody, and shared legal custody and that mom should discuss major decisions with Dad. Dad gets the child Tuesday and Thursday from 4pm to *:* pm and every other weekend from Friday at 4pm to Sunday at *:* pm. Holidays are shared. That's the schedule all year round, year after year. The father's home is in absolutely horrible conditions. Dirty, filthy, absolutely unsanitary. The child doesn't even have a bed of her own to sleep on. The mother over the last 2 years bought the Child a Queen Size Air Mattress for her at her Father's home. Mom and step dad bought the child a TV, a TV stand, a FIRESTICK to stream all her favorite shows on.Bought and brought to the Fathers home for the child to have there. Because her daughter was being subjected to sleeping on a filthy black floor from matted on filth. Having no TV, in a small public housing apartment that has had a cockroach infestation issue for the last 2 years. When dad was facing multiple failed inspections due to his home being so absolutely filthy, Mom left her home, her family, her * toddlers, and came to the father's home for * separate * hour days, cleaning a sight that only professionals in Hazmat suits should have been cleaning. The mother experienced several instances where she would pick an item up and it would literally fall apart in her hand and hundreds of live Cockroaches would pour out of said item and scatter every which way. Of course, the mother was not use to interacting with Cockroaches so these instances terrified her, however both the child involved in this custody dispute and her 15 year old half sister, reacted as if the mother was dramatic and stating "they crawl up the walls all day every day, it doesn't bother us really anymore ". That alone, was mortifying. The Mother's own child had become so use to living with cockroaches running up and down the walls and all around her that she now accepts it as normalcy. The father requested the mother switch his visitation days so as to accommodate his work schedule, changing his visitation from Tuesday & Thursday to Monday and Tuesday. This was over 2 years ago and the mother agreed to accommodate the father. The father consistently asks to pick the child up on days that are not his visitation days for odd things, the Mother always allow it in the best interest of the child. The father has not brought the child home at the appropriate time in over a year. He "brings her when he's ready to" regardless of also charging the mother $*.* to bring the child home. When the mother and step father decided to do the appropriate math of the distance between the mother and father's homes, the price of gas, and the type of vehicle the father drives, it came out to the father using less then $*.* in gas to bring her home. When the mother attempted to civilly bring this information to the father as paying the father almost $* a week in gas is truly a costly expense, the father ignored all evidence and stated quote "man can you please just send me my money yo". The Father was diagnosed with less then *% of his heart over 10 years ago and on May *, * the Father during a visit with the child experienced heart failure and the child was forced to call an ambulance and spent the entire night in the ER with the father, and was present when the ER Dr. Told her father he is suffering from Congestive Heart Failure and he needs to admit him for a few days. The Father, against the doctors consistent pleadings as well as his daughters pleadings, he ignored all of it showing reckless and irresponsible health risks to himself and the child and instead signed himself out. The Father has made highly inappropriate sexual comments to the child and the child's close friend who was present for a visit with the child at her father's during a very recent visit. The Father also took inappropriate photos of the two teenage girls while they were sleeping and quote "sent them to his boys". As a legal professional and mother, I can't imagine what grown 40 year old men are sitting around expecting random photos of some other man's teenage daughter sleeping. What exactly would be the basis for the men desiring these photos may be a better question. The Father has committed specific traumatizing acts against the child that have manifested into serious emotional and psychological trauma that the child is seeking treatment for by means of seeing a therapist once a week and a psychiatrist once a month. The child is actively being tested for a very specific and somewhat rare disorder created by extreme trauma that the girl endured at a young age. Conference officer falsely insinuated that the father and mother had been basically following a summer plan on some sort of mutually understood basis and that the mother, for no reason, was returning to the court order. This is incorrect. The mother only let the father, for one summer, due to the Father's summer plans he had made to do with the child for these specially accomodated visits. Never agreed or spoke of even in a verbal agreement as a "summer schedule" or labeled in any manner that would have insinuated the mother was agreeing to a summer schedule change in any official manner. Again this is a MOCK TRIAL AND THEREFORE DOES NOT VIOLATE ANY POLICIES OR GUIDELINES. SO I DO HOPE YOU ARE ABLE TO ASSIST AND NOT JUST SIMPLY ERASE THE ENTIRE COMMUNICATION.

Are you able to cite previous cases which the court has ruled in favor of the childs best interests against biased decision making?

Do i list the concerns for the child in the exceptions? Or do i merely reference that they were completely disregarded?

Ok very good. You have been extremely helpful thus far and i thank you for your assistance