It is incredibly relevant fo the judge to know that when the children are with the JW parent they will be subjected to five hours a week of conditioning that
1) Teaches them their non-JW parent is part of Satan and will be destroyed at Armaggedon.
2) Teaches them that they are not good enough for salvation themselves if they do not spend additional hours (ten) a month in field service trying to teach others the essential idea espouse in item 1.
3) Teaches them that education, recreation, art, music, sports, or any other type of interest healthy kids might have takes valuable time away from item 2.
4) Teaches them that because they have these interests (whether they are allowed to participate) and desire to participate, they too will be destroyed at Armaggedon.
5) Teaches them to "treat as dead" those former members of the church that have left, whether voluntarily or by disfellowshipping-and that this could happen to them too if they don't follow items 2-4.
6) Teaches them to lie when it is inconvenient to tell the truth, or when the person inquiring doesn't deserve the truth.
7) Teaches them that should they be abused or molested that going to civil authorities will subject them to item 5.
8) Teaches them that if they have friends that aren't JWs, those friends are all evil, and in turn, you children will become evil.
Then it would be important for a judge to know that the children will be kept out late two nights a week, and will be required to spend however many days, all day, at assemblies, special meetings and conventions, sitting quiet all day, listening to all of the above.
It would also be important for the judge to know that the JW parent would try to prevent life-saving blood transfusions.
And finally, it would be important for the judge to see the JW parent painted as an individual with a mental dependency on a quasi-religious organization, and that would cause the JW parent to put the organization's needs above the children's, perhaps to the point of shunning them should they at any point reject her belief system. Then demonstrate HOW HARMFUL it is for the children to be loved only conditionally, and that you fear for their emotional. physical, and spiritual well-being if their religious upbringing were left up to the JW parent. (Any facts about the JW parent refusing to miss a meeting when the child was sick, either taking the child while ill, or leaving them and not staying home to care for them?)
There is a lot more, but the legal standard with child custody is best interest of the child. The key here is to demonstrate how exposure to this religion is not in the best interest of the child.
Shoshana