Lawyer just emailed me back and said "I will try to speak to her lawyer before, if I can't, she will disclose that during the court conciliation session. You each say what you are seeking"
This is not a litigator. We know what the mother is seeking - total control with EOW for you.
Your deposition is not about what the mother is seeking, it's about why. She says experts think young children should be with their mother - that's a why. In trial, she will now have to prove experts actually say that - with an expert. You need the *why* to challenge the mother, not what she is seeking.
And Mr. Wonderful is not about you, it's about making the mother squirm in the witness stand - it is a point of discomfort that might cause the mother to . . . be more agreeable, if you know what I mean.
Here's how I would see this going. You do the mediation with this attorney, politely disregard anything less than 50/50, and when the mediation session has met the time required, you leave - instructing your attorney to depose the mother within the month. Determine if your attorney is a litigator based on the appearance at the mediation - if your attorney leans on you to settle for less than 50/50, bye-bye.