Problem
For a family law office in Michigan, I work as a paralegal. My supervising attorney has been requested to file an application to change custody on behalf of one of the firm's customers, Brian Miller, and his daughters, Jade (4 years old) and Shelley (6 years old).
His ex-wife, Shannon Smith, and he currently share joint legal and physical custody of the children, with each parent spending an equal amount of time with the children each day. Brian believes that this system has to be changed, nevertheless, for the following reasons: (i) When in Shannon's care, the children frequently skip school; (ii) Shannon has moved three times in the past year; (iii) Shelly told Brian that her mother and her boyfriend frequently argue, yell at one another, and this scares her; (iv) Shannon's work schedule has changed; as a result, Shannon's mother watches Jade and Shelley for a sizable portion of the day; and (v) Shannon was recently found guilty of a drug paraphernalia misdemeanor
My lead attorney has asked me to draft the brief's analytical section in support of the motion. How can I draft an analysis that covers each of the best interests criteria that the court should take into account when evaluating the motion and my stance on each aspect in a way that will persuade a judge who is reading the motion using the material that has been provided?