Divorces are quite ugly...especially when kids are involved. I, like many here, would suggest a lawyer, like, yesterday!

I'll go further...don't allow him to enter into any counseling with her, especially if she's been seeing the doc or counselor for awhile...they are automatically biased. Have him demand that a disinterested doc step in for counseling...one not known by either party or either attorney. My ex started taking my kids to a counselor that her attorney chose because she's sympathetic to the mother, and has been used as a GAL in the past. That doc made wild accusations about me, and wild claims about my dealing with the children...which is how I lost custody in the beginning. Once the kids realized that everything they told her was being filtered to their mom, and then to the attorney, they stopped talking to her. I ended up filing enough complaints against her, and got other fathers to do the same (I took out ads in the local newspaper), that she is no longer in practice...her license to practice was revoked.

Have him find a local attorney that is a Father's Rights attorney...they will know the proper steps he needs to take, and will help him get where and what he needs.

As far as the mother seeing a counselor...the courts see this as her recognizing that she needs help. Unless she's violent, abuses the child, abuses drugs or alcohol, they won't see it as a reason to remove the child.

Check the state laws on recording conversations and phone calls...some states, such as Ohio, require only one member of the call or conversation to know it's being taped. If he lives in such a state, have him record everything. It will go a long way to show instability if she's hot and cold with him, yells, etc. Granted, it isn't admisable as evidence, but you can give it to the Guardian Ad Litem for review, and they can use it to sway their decision one way or the other.

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1987 560SL
85,000 miles