Get a lawyer.
Whether or not you can afford a lawyer, write a paper on your experience with your ex.
Stick to the facts. State only what you know to be true. Second-hand news and guessing would not be considered relevant.
State how he as been with the child. Neglect, abuse, drug abuse, no-shows for visiting times, and abuse towards you in front of the child are valid concerns that the court will look at.
The court will not care what his love life is like, unless his love interest(s) is a known child abuser/molester that he plans to have around the child. The court has no interest in hearing about affairs or wild sex scandals, unless a minor is involved.
The court will not care about all his annoying habits or idiot things he has done if it does not directly involve the child. Avoid rambling. Keep the letter short (about 1-2 pages AT MOST.) Anything longer would only bore and irritate the court.
If he has had any run-ins with the law, documents proving this would be helpful, especially if they concerned drug use or domestic violence.
The court will not look kindly on you for saying you do not want your child to be with his father. It doesn't matter that the father is a bastard. Courts try and keep family together as much as possible. State in your paper that if the child should spend time with his father, they should be supervised visits and the father should pay for the supervision (which is costly. If he really gives a rip about the kid, he would find a way to pay for it. If he doesn't care about the kid, he will make up excuses not to have the visits.)
Your ex will write a paper in response to your declaration. Don't let this rattle you. It will describe how your points are lies and he'll very likely throw in some jabs about what a lying whore you are. Keep your cool. You will probably be given the chance to write a declaration in response to his response. Ignore the jabs and stick to your story. Don't sink to his level. Resist the temptation to jab back. The court hates petty bickering. Just give your side of the story in response and, again, stick to the facts and avoid rambling.
Heheh. You dont know. Thats why you never take a lawyer on a hourly rate. Your attorney done lied to you!
Always go for a contingent rate or retainer fee. I work for the worlds biggest collection attorney and do bill collecting throughout the U.S and have over 300 lawyers working on cases in every state.
Depending on what type of attorney you want, I may be able to hook you up with a good attorney on a contingency rate. He makes money if you make money. ONLY!!!
Email me if you want contact info...Exempt001@yahoo.com