Good to hear from you and hope you and the baby are doing well. Your argument sounds sound to me. I think it's good that supervised visitation is already part of the mix, as it shows your ex's parenting is already a question mark. And I also think the fact that your ex is so blustery and confident, but ultimately clueless to the point he claims to not even know what he signed, works in your favor. He'll either sound like an idiot in court for professing to not understand the document he signed (or maybe he'll go the victim route with it, but either way, I don't think the court will have much sympathy) or he'll get so pissed he'll show his true colors right there, all wins for you.
I don't agree either with the current mentality that the most important factor in custody is for the child to have both parents in his/her life (i.e. the topic of "parental alienation"), if it means that child is exposed to abuse and/or neglect. Unfortunately, that's not what courts think, and parental alienation seems to be the overriding theme in court these days.
I would tread very carefully here. I don't believe the phrase, per se, was brought up in my situation, but the concept was very strongly hinted at and by her own admission played a big part in our guardian ad litem's decision to largely grant NPDxh custody (my lawyer told the judge he just flat-out rejected the report in its entirety and the judge agreed to give us more time. In the meantime, my NPDxh proposed a settlement that gave me custody, but that was him, not the court).
......... The card I played in our custody battle was credibility. I started out with allegations of abuse and I stuck with them and cited them as reasons I did not want NPDxh to be around DS. ....... NPDxh, meanwhile, accused me of even MORE allegations, and more egregious ones, including but not limited to, the fact that he thought I was MENTALLY UNFIT to parent, and was a dangerous driver in whose car he feared for his son's life. But when the GAL came around, he professed to want to be one big happy post-divorce family who wanted to co-parent and encourage the HELL out of a relationship between me and DS.
Which, of course, made his entire affidavit either lies, or meant that even though he thought I was mental and a reckless driver out to kill our son, he had no desire to protect his child. So the "court" and GAL did not too good a job separating fact from fiction.
With your ex, I would only bring up the very worst instances of neglect/abuse, and always in terms of what's best for your child, who, you might want to point out, is still so very young. And never speak of your ex with rancor, even if he deserves it and it's justified. Always speak with compassion, because of course
your ex and your son to have a great relationship, but unfortunately (shakes head sadly), you want your son to be safe. I also would avoid putting anything in terms of trying to "protect DS from ex," which is exactly what you are trying to do, but that language is a PA trigger.
And Oh - My NPDxh to this day threatens lawyers and courts when he doesn't like what I have to say, and he, too, was soooooo smart about the legal system (read: not really). Haha. What's even more amazing is that after he threatened me and told me all about how courts work and how I couldn't leave, etc. (wrong wrong wrong), I got an emergency temporary custody order for our son and permission to move out of the marital home with him, which I did while NPDxh was at work without telling him
. Bye bye, NPD! And even after I did the very thing he told me the courts "would never let me do," he continues
to try to threaten me with legal moves, even though I'm the one who got the leg up on him in every single regard, and in every single hearing in court.
So remember, their bark is usually worse than their bite, and also, their bark is pretty much BS.
Fingers crossed for you in court. Take care and stay strong