I think your list is good. I would definately focus on H spending irresponsibly. Maybe focus also on cancelling plans with the kids, blowing them off, not being consistent. Also, you could talk about his lack of boundaries in YOUR house.
Is OW invited to be deposed?
Thanks, LWB!!! Plus I realized today he hadn't given my D8 her medicine (related to autism) last night or this morning, and he's forgotten several times (actually I really think most of the time he forgets and last week he said he gave her the morning dose really late). Just doesn't think about it. So I guess I should put that down?
I don't know about the OW. Really wouldn't want to have to see her but if I have to I guess I have to. Will my L invite OW to be deposed? She's divorced now so would that be relevant? What kind of questions would my L ask her do you think? I'll ask my L about that if you think I should.
Also, what issues re: boundaries? There are so many! You mean like when he enters my room without knocking or comes and yells at me? That kind of thing? Or is there something else I'm forgetting and I should put in?
I know what you're talking about the cancelling plans. When D8 was wanting to go to a play back at the start of the year and made plans with him to take her, he cancelled on her twice to go to a luncheon (I saw a bulletin re: the lunch in the back of his car although I don't look anymore b/c I'm afraid of what I might see!) and party with OW so I finally did take her the last night of the play. I don't think he's done that recently, but you think I should bring that up still?