Always ask for WAY more than you think you will need.
Remember that judges/court deal with dates/timelines/examples. Not, "I hate him, he's ALWAYS late."
Give a timeline to your attorney to back up what you are asking for.
Example:
May 5, 2016 - XH came to my home drunk wanting to see the kids. I explained that we had not talked about him seeing the kids on this day. I also explained to him that I would not be releasing the kids into his custody and care while he was intoxicated.
September 12, 2016 - XH was supposed to pick up the kids at 12:00 pm since there was no school. He didn't show up. I received a text from his neighbor saying he was passed out in the driveway. I repeatedly tried to call him at 12:15 pm, 12:45 pm and 1:30 pm. I received no answer until he called me on September 15, 2016 at 9:00 am.
I would like to insure that our children are not put into harms way regarding their father's alcoholism. I would like to request alcohol testing at drop off and pick up.
Something along those lines. ^^^
Provide your attorney with any written or names/dates of proof of his drinking.