Motion for Permanent Custody


I plan to enter a Motion for Permanent Custody in the next week. There has been a Temp. Custody order in place for 10 months now. The parent evaluation has been completed and is being mailed as of tomorrow to opposing atty, the court and myself. My question is, what would be a few of the stronger reasons/arguements to put in the motion for physical/legal custody to be reversed, if they are applicable. I have read thru “what is in the best interest of the child” of the NC laws and also have strong evidence that our child is being neglected and abused with the current temp. custody arrangement. Do I put all of this into the motion or leave it for arguement during the hearing.
Thank you


Your evidence will be presented at trial, not included in the motion.