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I have to write down 2 things I want my children's lawyer to know about their uBPD father.  Tips?

I reported him for child abuse (he whipped my children on their legs with a fiberglass dowel for planting garlic incorrectly- left multiple, horrible bruises). CPS sent me to the police who suggested a child protection order because kids were terrified of their father, prosecutor didn't press charges, CPS closed their investigation, I dropped protection order. He tried to get judge to put me in contempt for withholding visitation during the protection order. Judge did not. Now he is suing me for full custody (we currently have 50/50).

Of course it is so complicated. This will be our 3rd custody dispute (and he also sued me for our car).  He has been on his best behavior since this all happened.  It is killing me financially, but I am still ok.

In his answers filed with the court he accused me of all the things he does and says. He made all sorts of insane accusations and keeps bringing up things that were handled in previous modifications.  He somehow managed to legally 'prove' things that were not true in our previous cases.  We here totally understand the projection and crazy, but how do I deal with it?  Will just being the rational, calm parent help? And now I have horrible anxiety even talking yo my own lawyer.

Thank you all for being here for support!

I am not very familiar with your story and the specifics of your ex.

If I have to do this for my SD's mom, I would say
1) She cannot admit that she is wrong, and she will actually go to extraordinary lengths to "prove" that the person accusing her of something is "wrong".  This includes taking information out of context, telling lies, playing the victim, triangulation, doctor shopping, etc.

2) She is incapable of identifying SD's emotional needs. She believes SD feels the same emotions that she does, and because of that she is comfortable expecting SD to soothe her.

A friend of mine has an ex with NPD.  The children's lawyer was most shocked by #2 - she just could not wrap her head around the fact that the dad cannot see his kids' anxiety.  It took a little while for the L to come around. 

Does the children's lawyer know your ex's history of abuse?

He knows nothing yet. Just assigned to the case this week.

That comes first, then. 
1) ex is physically abusive, and include lots of examples
2) ex is incapable of identifying the kids emotions, blahblah, which makes him emotionally abusive - and include lots of examples

Do you have any insight into the GAL's qualifications and experience?  Is this a newbie lawyer or social worker?  Or does this GAL have a reputation as being experienced and perceptive?

Generally, courts are very reluctant to make major changes to custody terms without substantive basis.  However, don't assume H can't bamboozle the GAL or other court-associated professionals.

If H is making such huge requests, could you write up a response addressing the claims and then going one step further, asking that you get custody based upon ex's baseless claims?  Adding that if court is reluctant to change custody, then you ask for Decision Making or Tie Breaker status.

My point is that the current order evidently lets ex act out quite a bit and setting limits sooner will minimize risk of things getting so out of hand again.