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Unfit mother?

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My boyfriend and I are taking his ex to court for custody of their 3 year old (when I say I, I mean I'm just there for moral support, really), partially because we believe the mother is unfit, and partially because we want to legally be able to see the child (the mother rarely lets him see the child, and never lets him take her out).

I believe his ex is an unfit mother for a few reasons. First off, the mother is disabled. I know that's not grounds to say she's unfit, but the list goes on. My boyfriend has told me that on some occasions when he has gone over there to see his daughter, she has been absolutely FILTHY. I can understand that it would be difficult for the mother to do things that every mother must do (like bathing), but if it's that difficult, she shouldn't have had a child.

Also, about a month and a half to two months ago, the mother forgot to lock the door, and the child got out! She (the mother) had to call the police and tell them she couldn't find her child. It turned out that a tenant at the apartment where they live had taken the daughter in, but all I can say is it's a damn good thing that person wasn't a child molester or a killer! You never know these days.

Then there's the issue of the mother's mental health. There has been at least one time that my boyfriend knows of (it happened when they were together) where the mother was institutionalized for trying to commit suicide. About three months ago, she told us she had been institutionalized again for about two days, but she lies incessantly, so I'm not sure if that's true or not. The lying can be backed up because she has been expelled from 2 colleges for plagiarism (yes, plagiarism both times!) and falsifying medical documents.

I was just wondering if anyone has any tips of how my boyfriend and I can prove these things in court, prove that she's an unfit mother, because I can't stand the thought of that child being in that household anymore! Thanks.