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If you are petitioning to establish or modify child custody: Quality of the relationship with each parent. Ability of each parent to provide adequate care. Relative competency and fitness of each parent. Each parent's willingness to embrace the responsibilities of parenting.
Write professionally, but in your own voice ? don't try to sound like a lawyer. Be specific. Don't ramble or repeat yourself, and don't include irrelevant information. Don't lie or make assumptions not supported by facts and evidence ? include only information that you have personal knowledge of.
For legal custody, they will have to be in agreement to be able to make decisions together regarding their child. If parents are not able to come to an agreement during mediation, then a judge will step in and make a decision based on what they see as being in the child's best interests.
Current custody and child support order, you must file the Petition to Modify Custody and Support (?Petition?). If you are filing the Petition, you are the ?Petitioner? regardless of whether you were the Plaintiff or the Defendant when the custody and child support order was first entered.