BPDFamily.com

I have been through hell and back and back and back and back. And apparently I am back again.

My not soon enough to be ex is a very persistent blamer. and obstructive about every little thing and rages often

So I had 2 custody evals and got majority custody eventually, the kids were in therapy and they had to stop because my ex threatened the therapist. The therapist called me at home when the kids (d11, s7) mom took them in  and said I should try to get supervised visits until ex learned how to parent. So We went to court and had a 730 evaluator appointed so she could talk to the old therapist and report to the court.

The 730 therapist talked to the old one but suppressed what she said and made up stuff about me and is now recommending the ex get legal custody and they stay with her 4 nights a week.  

I am really blindsided by the outright lies by this therapist, she was talking to the ex exclusively and would not speak to me and she is basically stating ex's distortions as fact in her report.

It is very upsetting to me that this is happening now after everything we have been through all these years. I have always tried to do the right thing despite ex making everything difficult, I mean everything. So this really sucks.

Has this happened to anyone else?

Do you have a good lawyer?

I do at least through the next hearing, but I am not  going to be able to afford to keep her much longer.

What does she recommend?

Well, I do not know.  See I got blind sided by this report today and the hearing is monday morning.  The Lawyer was not in today.

A few months ago this 730 therapist made a report to the court after only seeing the kids for a month and the judge did not adopt it then.  the kids got ordered back to the old therapist at that point but the old therapist would not take them because of fear of my ex.

So, we had a special master that recommended that the kids see the 730 therapist again and I expressed my concern and itemized all the things I was concerned about that 730 left out of her report. The Special Master then quit.  So ex filed emergency hearing (because everything is an emergency) and the judge ordered the kids go back to 730 therapist until the next hearing, which is monday.  The 730 was not suppose to write another report as far as my understanding but she did.

The 730 only saw the kids 2 more times, 1 time I brought them and they were doing very well and in a good mood and were fine.

The 730 expert has stated things like the kids are completely stressed because I say bad things about their mom to them when I dont and I am certain the kids did not say that because it isnt true.  I do not do that, I say things like "I don't know why she acts like that sometimes" And I have told them that the things ex says about me are not always true, which is the case.  The kids tell me that she says horible things about me all the time. In fact the school psychologist informed me that the kids mom was saying things about me to the kids, another thing that was left out of the report.

The 730 expert even accuses me of waging an internet campaign against her. Which I didn't do,  She says I interfere with phone contact which I never have done not even once, says I interfere with medical care which is also not true. My ex takes the kids to the doctor way to much and I have had my concerns and expressed them.

So the report was sent out friday and the hearing is monday morning. So there is no time to gather the evidence to prove she is lying, except I was able to get the phone records.

I guess the part that bothers me most is that I know the kids are doing better when they are here and this therapist is painting me black just like ex did. I suspect that she may be the same way my ex is. 

Another thing that is going on is that the ex has been showing up with the police and harassing me during my custody time, saying its her time when it is obvious it isn't.   So instead of addressing the harassment the 730 sas that there have been problems with the transition from father to mother, the police have had to been call several time. 

This therapist got no information from the kids, I am pretty sure, she just played legos with them when I brough them. it is all the projections from mother.  She has been communicating with my ex but not me.

Do you know what the purpose of the hearing is?  That is, what will be decided Monday?

What is a "730" therapist?

I would suggest you call your lawyer early tomorrow (Saturday) and keep calling her, or even go to her home, to make sure you have the chance to get her help before Monday's hearing.

Maybe it will be appropriate to say at the hearing, "I only got this report Friday, and it has a number of statements in it which are factually untrue.  I need time to work with my attorney, to find out what options I might have, and to gather evidence to show that the report contains a number of false statements and that its conclusions are based on that false information.  I would like the court to grant a two-week delay so I can be prepared for this hearing."

If that won't work - your lawyer should know if delays are usually granted in situations like this - you might be able to prepare by making a list of the false statements in the report, and also a list of key points to make about the report - basically what you've said here, but in more formal language.  Maybe submit that as a motion to the court, asking that the report be thrown out... .?

A rat's nest, but you may want to do a little Google research on the 730 therapist?  Some try hard to keep their work history private where dealing with family court.  Granted, some of what you may find on the net could be sour grapes, but it's also true, where there's smoke, there's fire.  This may be handy to talk to your L about before the hearing.  Too many cases on these boards where this type of bias arises in family court.

So the T that has seen the kids, their mom, and you say ex is the problem. The 730 that has not seen you says you are the problem. That needs to be brought clearly in front of the judge. Make sure it is introduced as evidence and not just in testimony. Judges MUST base their ruling on evidence. The 730 clearly is not "objective". The evidence proves that.

If you have police reports,etc that show ex showed up when it was not her time and caused problems then that also needs to be introduced. If you have lots of info proving this then make one sheet with everything in a concise manner and the pile of evidence underneath. When you do that the judge is handed the entire thing. He/she does not want to go through it all. The judge will then hand it to ex and ask her if the top sheet is correct. Ex either agrees or goes through the entire pile. If she agrees, the top sheet is evidence. If she doesn't agree and they go through the entire pile that pisses off the judge. Either situation is a win for you.

Like Matt said you can probably get a delay if you need more time.

Yeah, this sounds like the right approach - prepare over the weekend the best you can, so if you can't get a delay, you can take the initiative and tell the story briefly - both verbally and with that top sheet as David says - and also with as much backup information as possible, so it's clear to the judge that your description of events is supported by evidence.

Sometimes these hearings are very brief - you may not have time to make your case - so if you are prepared to summarize it briefly but clearly - make your key points very clearly and briefly - you may be able to establish what is going on.

One problem you might encounter is that you'll have to make the 730 therapist look bad.  Usually courts give a lot of weight to what the "neutral" professionals say, and less weight to parents fighting with each other.  You can speak very respectfully to and about all the professionals involved - always calling them "Mr. X" and "Ms. Y" - but still make your key points... .

"Ms. PreviousT met with Ms. Ex, and with Child, and with me, and considered all the aspects, and recommended that I have custody, and since I have had custody, Child is doing very well in school, emotionally, etc.  Then Ms. 730T met only with Ms. Ex - not with me - and issued this report late Friday, and her recommendation is at odds with Ms. PreviousT's recommendation.

"But there are a number of statements of fact in Ms. 730T's report which are objectively false - I have noted them here and I have copies of this for everyone - and I can back up each of those false statements with evidence if I have a little more time to gather it up.  Specifically, there are a number of accusations in this report which are not true and which are not backed up with any evidence at all - she says I did X, and Y, and Z, and I have never done any of those things.

"I would have been glad to go over all those issues if Ms. 730T had met with me before issuing this report.  Since it was prepared with input from Ms. Ex but not from me, and since it contains a number of false statements and accusations, which are not backed up with any evidence, I would ask the court to set it aside and not to consider it at all - it is not a fair and objective report."

Make sure you say very clearly what you think the court should do, or not do:

"I ask the court to take no actions regarding custody now, and give me two weeks to gather all the information to show which statements of fact in Ms. 730T's report are not true.  I would also be glad to meet with Ms. 730T during that time, and give her all the information I can, so she might consider revising her report accordingly.  And we can bring Ms. PreviousT to the next hearing so she can speak to the court about her findings." (or whatever you think are the right steps for the court to take.)

Ideally your lawyer will help you prepare but she may not be available or willing to help for whatever reason.  You may have to do this yourself, and assume the worst case - that the court may not grant a delay and you may have to make the best presentation you can on such short notice.

If you have a little more time, one approach you might consider - it helped me a lot - is to depose your ex, and maybe the 730T too.  I filed a motion with the court asking that my ex be deposed - questioned under oath by my attorney - and it was granted.  The other side responded in kind, so we were both deposed for four hours - my wife in the morning and me in the afternoon.  That got both our stories down on paper - a court recorder - so then my lawyer and I could gather the evidence needed to prove she was lying.

What that did was put my wife's lawyer in a very difficult situation.  My lawyer was able to take some of our evidence to my wife's lawyer, and say to her, "Your client made a number of false statements under oath, and we have evidence to prove it - here it is - this will all be shown at trial, plus more.  If we go to trial, we will put your client on the stand, and confront her with all this evidence, and she will have to either admit she lied under oath, or double down on her lies, which will make it even worse.  Now... .would you like to settle this case?"  An attorney has an ethical obligation to protect her client from criminal liability, so my wife's lawyer had to advise her client, "We better settle and avoid a trial no matter what."  We were able to get a much better settlement than we could have before deposing my wife.

For your case, since you're not talking about a trial, depositions might play a different role - I don't know how the process works where you live.  That's something your lawyer should explain - all the options available to you and which she recommends.

hi jay. my situation is not the same as yours but I too have a BPD stbxw and have been subjected to blindsiding followed by a conspiracy of silence. I know the shock and violence of it. I have no legal advice but you have my complete support.

I agree, try and get a continuation to prove that the report has many factual errors. 

You might be able, today to go to the police department to order the incident reports concerning them coming to the house during your custody time.  Doubtful you can get them today, but it gets the process started.  At the least you can find out who to contact Monday to get the reports.

Ditto with the doctor's office.  Appointment dates should be easy to compare to which parent at custody at the time of the visit.

Only one point of concern from what everyone has said. I would not feel comfortable saying I would be willing to see 730T. 730T has already issued a report without talking to all parties.

I would question anything from 730T at this point and into the future.  730T is not competent because of the actions already taken and has exhibited an obvious bias and/or lack of professionalism. Those actions expose the incompetence so I see no reason to continue this course of action. We already have an unbiased report. If ex thinks the unbiased report is incorrect she should be ordered to assume the majority of any costs for an additional unbiased report. Also, both parties involved should be able to choose who the new evaluator is so as to eliminate or minimize any future possible bias.

So David, you're saying that 730T has showed her colors - showed her bias - and it's not realistic to expect her to act in an unbiased way in the future.  So meeting with her will just make her look fair when she's really not - is that right?

That might be right.  It would be great to be very open and not fight with 730T or anybody else, but maybe that's not realistic... .

About the incident report... .

My lawyer advised me to get that from the police after my wife attacked me and accused me of hurting her.  I went to the police station and paid $5 and they prepared it for me and gave it to me a few days later.  They had blacked out some stuff but not much.  It was very useful in showing what had really happened - the police report proved that my wife was lying.

We had a very biased therapist, too, and were able to show her as biased and not dealing ethically with a high conflict situation.  Any competent therapist of children, especially in a high conflict situation, will try to meet with each parent before ever meeting with the child.  DSD's therapist did not do that, and she was thrown under the bus because by the time my DH found out who she was, she was already hating my DH based on BPD mom's lies about him.

Not only that, but I don't believe that ANY therapist can make recommendations on possession and access of children WITHOUT a thorough custody evaluation--she could lose her license for doing so.  In fact, I would google her ethics code and get some questions ready to slam her on the stand for that.  You could also file with her state board.

I may be filing a complaint not to get even but because it is the right thing to do. She is a very dangerous person and has no business doing what she is doing, I would not want any other concerned parent to go through this with out fair warning.  This has cost many thousands of dollars and the kids have not had an effective therapist for at least 6 months.

730 is a California family law code. 730 is a person  that can report to the court w/o waivers from the parents.

We had a thorough custody eval with a phd last year, and as a result I received majority visitation time and Joint legal. Even with two arrest, one fpr punching me in the face in front of the kids then calling the cops on herself and one for holding my son upside down in his full body cast while in full rage and then almost taking my eye out, I did not get legal custody. The contrast between this thorough report and this womans emotive thrown together report is astonishing.  I really  knew I was in trouble when I received emails from the therapist containing multiple exclamation points "!"  I expect there is a reason she has bonded with my ex.

She did not contact my collateral contacts and contacted the exs. Then stated hearsay of exs distortions in her report as fact.

I like the idea of the topsheet, thank you. I am going to put together what I can.  I have the police logs but they dont say much, no incident reports were written because they just yelled at my ex and told to get in her car and leave. I do have pictures though of her in front of my house with the police I will get together everything I can and bring copies.  The thing is about the police is, the ex knows I would not do that to the kids when they are with her. At the old house the kids in the court could not come inside our house because the cops kept showing up and ex use to scream in the back yard and everyone could hear her.  Now at my new house there are a bunch of kids that are in and out of the house and I do not want the cops showing up.  So for my ex this is a very effective way to harrass me, just grab an old order, ad some distortion and the cops are at my door and I am having to prove it is my custody time and the neigbors get concerned.  The only thing that ever happens to her is the cops yell at her, then she does it again and again. There is nothing I can do, I cant get a restraining order keeping her from calling the police or one to keep the police from coming to my house. 

I will not be meeting with the 730t again, she has asked my lawyer for me not to email her anymore, yet my ex still copies her on every email she sends, but I must not copy her on reply, which is what I was doing. I do not trust her, I do not trust that she would tell the truth regardless of how fruitful the meeting may seem. Just like the ex, I will not put myself in a situation where I am alone with her nor communicate with her in any way that I can not retain proof of everything that has been said.

I also like the idea of dispositions, that sounds like a great idea in fact.  I would love to depose both my ex ad the therapist. I am going to be bringing this up with the lawyer asap. This makes perfect sense to me. It is very unlikely that my ex would not lie and the therapist misdeeds would be easily exposed.

As far as stress and all, this threw me for a loop, it must have triggered my ptsd, I was very anxious and had a hard time sleeping last night. Now the next day I feel better and I keep reminding myself that the stress is counter productive and I win by staying calm and centered. it's not easy though.  I think the part that bothers me the most is the claim that the kids are stressed because of my bevavior (talking bad about mom). My ex does that, not me, I have been careful not to that because I understand how it effects the kids. It has been really hard with the kids coming back from their moms being stressed and regressed and to have this woman make this claim hurt me very much.  I suppose I have gotten use to projection from ex, but to have them believed and stated as fact by a "professional" is very disheartening.   I try to think of the big picture and as horrible at it is to say, I take some comfort in the almost certainty of the ex screwing up again. She will again, and again.  That is how she is hard wired. 

Depositions aren't super-cheap though.  I had to pay my lawyer for a few hours of her time to prepare, plus four hours for my wife's deposition, plus two hours for mine.  (Mine didn't take as long because I told the truth.)

But very effective if you plan well.

Yes Matt. Also most people have difficulty saying they made a mistake and they are willing to own it. The 730T , if that is the case, will only back up his/her original recommendation to protect himself/herself. That is human nature to a large degree.

The county in Pa that I live in has what they call CCES. It is a hybrid eval process that is inexpensive compared to a private eval. The problem is that what the evaluator writes is considered evidence and the evaluator can not be brought into court to be questioned about what they wrote. If there is a bias/incompetence/etc  you have to hire a professional evaluator as a witness to debunk the eval that was written. That costs more money than a private eval or close to the same amount. It's a big business with lots of money. The last thing of interest is the best interest of the children. Yes I am cynical about the family court system.

The way around CCES is to refuse to sign the agreement. Then you have to either stop proceedings or get a private eval. If the other party refuses the private eval then the majority of the money comes out of your pocket. They charge the opposing party the amount for half of a CCES. That is supposed to counter any claims of bias since both parties paid something.

Another thing. If the police show up let them know that you want the police report and ask them when you can pick it up. I believe police are required to write a report every time they are called. Letting them know you want it makes them do what they are required to do. That worked for me.

I believe the custody evaluator's know when your $ is low.     You'd be less likely to pay to rebut the report then.     I am trying to throw out my biased report without having to go through this expense.     I feel the bias and incompetence is so obvious that there should not be a need to hire experts to rebut it.

The police here do not have to write a indecent report for every call,  there is a log book with all activity.

I did express to all that I was low on money and I am running out to be honest. Fortunately, by the grace of GOD, I have  been offered an interest free loan from someone who has been following the case and I will be able to keep going with the attorney.  I have have been able to find evidence already to debunk 1/2 of what she is saying in a 20 minutes review of emails and I should be able to have a packet together by tomorrow.

I did screw up and while upset told the therapist that would not want her giving therapy to my pets much less the children.  I do not see how this can be construed as a threat, however, as she is claiming.  I broke my cardinal rule of wait 24 hours before responding to something upsetting.

I would rather be in debt and sleep soundly by doing the right thing than not be in debt and toss and turn all night. I will be debunking the report the best I can, I should be able to find evidence to debunk almost everything she is claiming actually.  I will provide evidence when I can and I will make truth public record.

Time is short, but if you have time, you might want to prepare in another way too... .

Look in her report, and note every negative thing 730T says about you - make a list.  Then look through all your e-mails and find anything that you wish you hadn't written, and add those to the list.

For each item, write down as briefly as possible your response, in the form of "talking points", like this:

* Blah blah blah.

* Blah blah blah.

Etc.

For some, the response may be, "This is false and is not backed up by any evidence.  I have never done X."

For others, the answer might be, "I wrote this when I was very upset at what 730T was doing.  I wish I had not written that.  I have never threatened her or anybody else."

Or whatever.

So you will be very prepared, and not tongue-tied, if any of these come up.  The ones in the report, if you are given the opportunity, you may want to bring them up and give your brief response, to support your request that the report be set aside.

The other ones - not in the report but in e-mails or something else that could come up - you won't want to raise those issues but you can be prepared so you won't be caught off-guard if they come up - you quickly go to your talking points and defuse them without denying anything that you actually did.

When I won my Change of Circumstances case so I could proceed with seeking legal custody, the magistrate included a couple pages of case law citations emphasizing that bouncing legal custody back and forth between competing parents is something the court avoids.  It does not like to change legal custody without real and substantive basis.  Is there some law, case law or policy stating that in your state?

Also, if you can disprove a significant portion of the claims, then you would have basis to claim the other parent is "not credible" (and the 730T also based recommendation on information that was false or "not credible".  Courts hate to call either parent liars, probably doubly so for a professional.  Maybe you can call the claims "false" or "contrary to the facts" (or totally "unsubstantiated", another legal euphemism to avoid calling it what it is) and the ex "not credible"?

California does have a "vexatious litigant" law where a person would have to apply to a judge before a case could be filed and proceed, though it is rarely ever triggered.

Yeah, my lawyer told me to say "false statements", "false accusations", etc. - not "lies".

Saying "She lied" puts the burden on you to show that she did it deliberately;  she knew that it was false when she said it.  That is often hard to prove, especially when time is short.

But "That statement is false and is backed up with no evidence." puts the burden on the other party to back it up.  Several statements like that - "Ms. Ex stated that I did X.  That is false - I never did X - and she has not backed this accusation up with any evidence." - will make it clear that what's in the report is not to be taken as true.

So, I just got back from court. The good news is that the activist therapist is no longer on the case and the kids will be getting their own lawyer. The bad new is that the split week schedule was adopted pending the next hearing at which point the judge wants to here from the kids attorney. A new therapist will be appointed too, one that is not a 730 and who will concentrate on the kids.

Could be worse.  Now if we can get some fair objective professionals.  I hope I do not end up with another activist representing the kids. I think there is a better chance of an attorney being objective. I hope the new therapist is good as well. 

The file is getting pretty thick

Whew!  I am so glad.  This sounds expensive though.

I don't understand why there are so many bad and biased evaluators out there.  They just end up playing god.

I am supposed to go to court on Monday and it seems to me that maybe I should just drop my own motion... .it's fairly toothless now and it seems like courts and evaluators only make everything worse.

What has the schedule been up til now, and what will it be now (at least temporarily)?

You were hoping to keep it as it is?

And I'm sorry but I don't remember how old your kids are?

Do you have a say on who the professionals are ? If so talk to your atty or others to guide you. IF you can get time to do that make sure you get it. It could make all the difference. Perhaps you can ask the evaluator that gave the positive report who they would recommend. Get more then one recommendation if possible.

Up until this summer the kids (d11, s7) have been with me 80%, and with ex EOW and 1 overnight the alternate week. so it is a big change. It was back to the way it is before the last custody eval. Now it will be kids with mom sat7pm-weds9am (4nights/3days mom  - 3nights/4days with me), back to where we started almost 2 years ago,  a very stupid schedule, IMO

Up until recently every professional on the case has come to the same conclusion, that my ex's time needed to be limited.  Now, though with the 730t's two reports on the record, I think the judge didn't have much choice but to allow her more time and see how it goes.  I think it is about 8 weeks until the next hearing.  The judge said at the hearing that he does not have the information he needs about how the kids are doing now because the special master quit. SO he wants to hear from the kids attorney at the next hearing.

This has been a setback but I am happy that the 730t is off the case. The judge said "She's done" And the judge was clear that this custody arrangement is temp to see how it goes.  I think the judge has a good understanding of what is going on but like everyone here says, they have to rule on the evidence and now there are two reports from the 730t which are stating ex's distortions as fact. I will spend some time gathering some more evidence on the false statements that I can prove.  

I do have a say in who the new professionals will be. If we cant come to an agreement the judge will pick. My attorney thinks that if the kids have there own representation I can relax a bit and I would not really need her anymore, perhaps on a consultant basis. I just want the kids to be okay and I am grateful that we have a good judge and I pray that the kids receive good representation.

Ex was very angry in the hall after, the woman has very pour impulse control, no ability to keep her mouth shut, she has much rage toward me still, kind of scary.  To be honest, I am always looking over my shoulder because I do not know what she is capable of resorting too.  

If she pulls it together and can be a good parent then fine let the kids stay there more, that would be a good outcome for the kids, but I am almost certain that it is just a matter of time before she screws up. All those years that I was so enmeshed, people would tell me that and I could not see it. I am able to see it now.

She can't play her distorted role as victim of the corrupt court system that gave custody to the kids abusive father anymore, which is her new thing.  What is she going to do for her drama fix now?  And she is going to have get the kids to school 3 mornings a week now.  


In her last declaration she accused me of not allowing phone contact on specific dates and I have records that show she talked to the kids. It was clear that she was harassing me with the police on my vacation time at the last hearing, and it was clear she had refused to return the kids for my last vacation week. She faced no consequences at all for these things. That is pretty frustrating.

Ah, but the case is still open.  No finding was made, just a temporary order, right?  So don't give up on disproving her claims, they should still be addressed.  However, it will be very easy for such basic incidents to get swept under the rug and ignored with the mass of things occurring.  It's up to you to keep those refutations alive and at the judge's fingertips.  Lawyers and GALs can easily let it slide and be forgotten.

Your attorney should tell you the best ways to get factual information in front of the court;  for example, you may be able to file a written response to 730T's report.

Make sure that for every false statement in the record there is a written document of the truth.

I feel I need to file a response too.  I brought everything to court but wasn't able to get it on record. It went quick and the therapist got booted first, then  the kids got a lawyer, then he went on a bit about how he doesn't have the information about what he needs about how the kids are doing, asked how long we had been doing the week on /week off in the summer and it had only been like a month. So he ordered that we split the week till mid nov. and he wants to hear from the kids lawyer who will talk to everyone. I could at that point have spoken up about the falsities in the report and what evidence I had sitting in front of me, but what he was doing seemed fair and I thought it important to remain calm and am almost certain it would not have changed the outcome. This has to happen sooner or later anyway, that they give them to her more and see how she does.

My lawyer is very smart but she never told me that I need to get the response to the report on he record. That makes perfect sense. I need to discredit it as much as possible.  

She accused me of emailing her after she asked my lawyer not to, which I did not. How can you prove you did not email someone?  

So there are going to be several types of false statements in the report and maybe in other things the court has seen or heard;  maybe even things said in court.

My suggestion would be, to gather all that in a list, with four columns.

The first column is "False statements" - repeat word-for-word each of the statements made by your ex or her attorney, in writing or verbally in court.

The second column is "Source" - tell where that statement was made - for example "730T report page 3" or "Statement made by Ms. Ex'sL in court, 8/15/14".

The third column is "Facts" - tell specifically what did or didn't happen.  In some cases, if the accusation is, "Mr. Jed e-mailed Ms. Jed after Ms. Jed asked not to get more e-mails.", under "Facts" you might put "Ms. Jed e-mailed Ms. Jed'sL on 1/1/14 asking that Mr. Jed not send Ms. Jed any more e-mails.  Mr. Jed has not sent Ms. Jed any e-mails after that date."

And the fourth column, ":)ocumentation" or "Evidence".  Reference whatever evidence you have, as "Attachment A - e-mail from Ms. Jed to Mr. Jed 1/1/14" or whatever.

In the case of the e-mails, you can attach the e-mail showing what date she asked you not to send any more e-mails, and you can state, "Mr. Jed has not sent any e-mails after that date, and Ms. Jed has not provided to the court any record of e-mails sent after her request."  Put the focus on the other side to prove their accusations.

Part of the impact of this will be the length of the list.  The judge may not even read the whole list, much less all the evidence attached;  she might pick out a few and check them out.  But seeing how many false statements are on the list, she should come to the conclusion that your ex is saying a lot of things that you say aren't true, and that you are offering lots of evidence that they aren't true, and that the other side is not backing these statements and accusations up with anything.

I did this - at my attorney's request - after my wife was deposed.  More than 40 false statements and accusations, some of them easily disproved, and others not so easy, but we put them on the list anyway, to make our point.  If we had gone to trial, this list would have been a big focus - my wife on the stand, confronted with each of these, and asked to explain the evidence which showed each statement was false.  It would have taken hours, and she would have looked horrible - she would have probably broken down at some point and her credibility would be completely gone, and it would have been pretty clear she had some serious problem or she wouldn't have made so many false accusations.

By the way, I would suggest avoiding the word "lie" completely, because I think it puts you on the defensive - if you say "she lied", the burden is on you, not just to prove that what she said was false, but also that she knew it was false, and that's often very hard.  If you say "False statements" and "false accusations", and if you know for sure that each statement is false, and can't possibly be proved - leave off the list any that are iffy - then you can't go wrong, because the burden will be on her to show evidence (though maybe not "proof" that what she said is true, and if it isn't true, she won't be able to do that.