Yes, if i was you I would put all of that in my affidavit. And also ask for what ever you want in your orders sought under motion. Its your motion, ask for whatever relief you want which is within the jurisdiction of the governing statute - support, custody access, etc. Its just given the established facts in your matter and your knowledge level you would have an up hill battle going outside of the box at this point I believe. You may want to review your rules of family court - should be on line. Will be helpful.
Printed copy · Anthology Volume 1, page 1137Printed copy from The Tender For Law Anthology, Volume 1, page 1137 (printed 14 June 2014). Added by this site; not part of the Facebook export.