If your question is “do I have a good chance of winning custody” I think the answer is “yes”. I’d say you have a very good chance. To strengthen your case, youmight want to do the following:
formally accuse your ex of abandonment. Many men loose out when the wife demands a divorce and they move out of the family home. Then the ex accuses them of abandonment and the father is toast. Do the same thing here – file papers accusing her of abandoning your daughter.
make sure your daughter WANTS to live with you. I’m sure she does, but have her ready to tell the judge that.
File “Innocent Spouse” forms with the IRS. This MAY save you from being prosecuted over the ex’s fraud.
Get proof of the dangerous critters in NM. Otherwise, the judge may force you to fly your daughter there against your and her wishes.
These lies you mention – again, get PROOF. HARD PHYSICAL EVIDENCE! Judges like that stuff and won’t give you any credit without it. Don’t demand that she prove what she is saying — you have to prove she’s lying.
See if the therapist will support you either in person or with a NOTARIZED letter. My son’s therapist supported us when we went for custody and it helped a lot.
Get enough money. You’ll need it to pay your attorney. I always use sites like Elcloans to apply for loans online – it saves a lot of time and efforts!
Be prepared with a WRITTEN parenting plan. How will you raise her alone? What changes can you/will you/have you made in your life and work to make sure she is cared for? What about interaction with the ex’s parents? And include all the potentially embarassing stuff like what will you do when she has her first period?? (Thank god I’m raising a son!!!)
Silly stuff – make sure (MAKE SURE!!!!) you know the names addresses and phone numbers of her teachers, best friends, doctor, dentist. it floors judges when ANY father knows this stuff and shows you are interested and committed.
If I think of anything else, I’ll let you know. I think absolutely you’ll win but always BE PREPARED!! Good luck