I assume from your question that you are representing yourself and calling these witnesses to help your case.
What to ask depends on what facts you want each of these people to talk about relevant to the child custody issue. The child custody issue in an initial determination case is: "what is in the best interest of the child?" So the questions need to help the judge address that question. For example, a day care provider could be asked which parent appears to be more involved in transportation, care, etc. of the child.
There is a lot more to it, and I urge you to get a lawyer. If you can't afford a lawyer to go to court with you, then you should at least find one to consult with one to see if you can get any guidance on how to present the case to the district court judge.
Scott Allen is a divorce and family law attorney in Wake County, North Carolina with over seventeen years of experience. He can be reached at 919-648-0658. DISCLAIMER: YOU SHOULD SEEK THE ADVICE OF A QUALIFIED ATTORNEY IN YOUR AREA TO ANSWER YOUR SPECIFIC LEGAL QUESTIONS. SCOTT ALLEN IS LICENSED ONLY IN THE STATE OF NORTH CAROLINA AND THIS RESPONSE DOES NOT CONSTITUTE LEGAL ADVICE AND DOES NOT CREATE AN ATTORNEY/ CLIENT RELATIONSHIP. RATHER, THE RESPONSE IS IN THE FORM OF LEGAL EDUCATION AND IS INTENDED TO PROVIDE GENERAL INFORMATION ABOUT THE MATTER IN QUESTION. ALTHOUGH A RESPONSE IS PROVIDED TO THE SPECIFIC QUESTION, THERE MAY BE OTHER FACTS AND LAW RELEVANT TO THE ISSUE THAT THE QUESTIONER HAS LEFT OUT AND WHICH WOULD MAKE THE REPLY UNSUITABLE. THEREFORE, THE QUESTIONER SHOULD NOT BASE ANY DECISION ON THE ANSWER, BUT SHOULD CONFER WITH AN ATTORNEY IN PERSON AS SATTED ABOVE REGARDING THE SPECIFICS OF HIS OR HER CASE
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