Your legal losses evidence that you are in desperate need of representation. Going against a seasoned attorney, the deck is stacked against you.
You may ask whatever is relevant or is likely to lead to relevant evidence. Once again, this needs to be skillfully drafted; but you need such evidence if you have any chance to prevail.
Now, if things are done correctly, you have an excellent chance to win on your visitation petition. By law, you are "entitled" to "reasonable visitation."
As for the boyfriend, the key would be to demonstrate to the judge that his bad acts directly impact the child. You need a carefully crafted game plan. Otherwise, you will walk away with little to nothing to show for your effort.
Consult a qualified attorney immediately.
The author provides the preceding information as a service to the public. Author's response, as stated above, should not be considered legal advice. An initial attorney-client conference, based upon review of all relevant facts/documents, will be necessary to provide legal advice upon which the client should then rely.
If you are looking for 216 Requests to Admit, they will not be especially helpful to you. As for interrogations, those are what the police do with suspect. You are looking for marital interrogatories and custody interrogatories. Samples can be found in any law library. The problem that you have is that you are pro se and your case is very complicated. You petition is for visitation. Showing the judge that your (ex wife? former girlfriend? mother of your child?) allows unsavory personas around your child(ren) does not help your visitation case. First of all, you have not mentioned that this allegedly horrible person poses any danger to your child(ren). Second, that person has no relevance to your seeking time with your child(ren). Please bite the bullet and hire a lawyer. You are in so far over your head that you run the risk of harming your own case. Best wishes to you.
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