Quote Quoting Dogmatique
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Given the apparent nature of Dad, I would be wary of that if only to prevent her from having to go back and forth in the interim. If she files first, she'll be effectively nipping it all in the bud, and getting the court's approval will ensure that Dad can't manipulate her or the court any longer.
I don't entirely disagree with you, but there are also risks in doing it your way...and associated costs. I don't know that dad manipulated the courts in the first place. To me, it looks more like he simply opted out of parenting entirely. Perhaps what would be best for mom to do is to get a simple consult with a local attorney.