concise narrative statement for contact

[butterflybee]

Hello,

I've been asked to write a concise narrative statement about contact in response to my ex's statement. He's made an application for residence, contact and several prohibited steps or specific issue orders. He is also self representing and keeps changing his mind in statements about what he actually wants. There are other issues as well.. he yelled at my lawyer in court, sends 5+ emails daily, is already threatening to both appeal and has asked my lawyer to be a witness for his complaint against the judge.

Sorry, that bit was a rant. I want to know what is most important for me to focus on in my statement. Do I need to respond to everything he's said? He has writen more than 100 paragraphs, some truthful and some not. A lot of what he wrote focuses on the past - he reaches the past 6 months on page 14.

Obviously I need to focus on what is in the best interests of the children and respond to the points in the Children's Act list (The ascertainable wishes and feelings of the child etc..) but I would really appreciate any further guidance.

Thank you

I have never seen one so am not the best person to ask but I do think somewhere, even it just an appendix to your statement you should go paragraph by para against his as if you don't you may be taken to agree with his version of events.

I would start with saying what your document aims to achieve eg it may be your response to his statement or it may be your suggestions for contact, I think the former not the latter.
You could start by saying you want things to be amicable, you have proposed XYZ and think that is workable and in the interests of the children, that it accords with one of his requests but he has made 5 and you are not sure what he is after, and then go on to comment on his.

I don';t think there needs to be any reference to how many emails he sends etc. He probably feels very upset and loves his children and wants to see them and needs to calm down.

He does see his children, alternate weekends and 1 weeknight on the other week. They are 3&5, so still very small and attached to their mother, who works part time in comparison to his 40+ hours. They are watched by his mother or sister when he has them this amount. Also, I moved out a year ago. How long is it reasonable to receive that number of emails? This is a reduction, it used to be 20+. Is there anything specific I can do to encourage him to calm down?

Can I make a blanket statement that I do not necessarily agree with points 1-120? This is where he starts talking about current proposals rather than the past. He is requesting more than 50% contact.. so my proposal does not accord with his. I do like your phrasing, though. Thank you for the suggestion.

Yes, you could. If his sounds like a ramble with not much sense to it and just going over the past it will not likely be taken much notice of but if it has useful content eg he is saying on 6 March you locked the children out of the house then I would definitely respond to contradict what he says otherwise his view will be the only one on record.

If the children are 3 and 5 and most ly with their mother then he is not likely to get more than 50% contact. I worked full time from when our children were 2 weeks old as did their father so our contact issues were always going to be different from a parent who is home more.

If he is emailing you directly and you don't have a lawyer to tell him to write to instead you could just save them up and only read them every 3 days and read them at once. An email is after all just a request to read it, not an immediate demand which must be read now. YOu could certainly write to him saying you are finding 5 emails a day too much and can he just send at most one unless you have replied to his last and he is just replying to that.

His emails go straight into my 'divorce' file in my email, unless he uses a different email address or texts, and I have requested he reduce the volume and/or focus on one issue at a time more than once. I'm afraid it doesn't last more than a few days.

Thank you for the perspective. I'll have another read through and make sure I respond to anything very damning.

If you have legal representation his emails should go to them and your lawyer should tell him they must go to them too.

He cc's my lawyer in all the emails, but not the texts. I just counted, there are more than 60 in the last 3 weeks. She (lawyer) has written him to suggest this is harrassment and recommend I speak to the community police service for advice. That's coming up, I just need to submit my statement first!

Agree with Xenia - if it is a long windy statement, reply by saying something like 'the Applicant refers to a great many historical matters. I do not agree that his recollections are necessarily accurate. However, I do not think they are particularly relevant to the issue of contact so I will not address each one in detail as i jabe been ordered to produce a concise statement. However I reserve the right t produce fuller evidence at a later stage should the court consider these issues relevant'.

But younmust deal with any serious accusations such as violence, drug abuse etc.

Thank you for all the help! It's submitted, I decided to reply point by point and my solicitor can take bits out if they're not necessary. Even so, it's half the length of his!

Now on to the next problem...