I am asking for him to have Saturday through Sunday morning and three hours in Tuesday and Thursday and more time once she turns three that's not good enough for him he wants sole custody and for me to see her as we agree.
"As we agree." If that gets into the order, you'll of course never get any agreement from him. Most courts start off with default boilerplate that is purposely vague, expecting the parents to work out the details along the way. Sorry, only works when there are two reasonably normal parents. Beware of "
reasonable telephone contact" and "
mutually agreed exchange locations, etc." Such vague phrases invite reinterpretation of the order.
So another theme you need is that you want both parents to present a good environment to your child, that dad sitting at home all day not gainfully employed is (1) not a good example for your daughter and not providing for her and (2) parenting is no
excuse not to work. Very soon she will be in preschool, kindergarten then grade school. Then there will be even less
excuse for him to sit on his fanny, getting support from you or the government just because he's a lazy bum.
Sounds like he's a slippery character and without a multi-pronged strategy to counteract his lifestyle you'll risk ending up being ordered to support his laziness.
Frankly, he will never get sole custody unless he can (1) document you are abusing, neglecting or being dangerous to your child, or (2) you acquiesce and give in. His seeking sole custody is all hot air and entitlement. He either thinks he's slick enough to get it, thinks he can wear you down or may have nefarious traps for you.
Problem is, its the old spitball strategy. Remember the miscreants at school? They knew that if they blew enough spitballs at the chalkboard that some of them might stick. Don't be won down, overwhelmed or outmaneuvered. Better to be
proactive than just defensive,
assertive than passive.
About the weekends... .Are you talking about every weekend or alternate weekends? Frankly, it ought to be alternate weekends, it will give him a chance to have a weekend off and one for you too. (Alternate weekends is a common standard in every court, it is time-proven, though exceptions are made for emergency responders and other professions that have to work some weekends.) If he gets her every weekend then you'll never have free weekend to go visit family or go out of town for a few days for whatever, not unless you declare a vacation. In my county vacations are limited to 3 weeks total per year. You need more than 3 weekends per year away from him.