You can say the Mother is manipulating the child. Or things like the Mother is actively discouraging the child from seeing you. Or describe the behaviours and say the Mother is creating a conflict of loyalties for the child. Having said all that, it is better to be cautious when not presenting evidence, at saying these things, and to skirt around it. Those things are more for a final hearing where you can evidence what you say. And even then, while a Barrister may be able to say that, if you, as a parent, say it - it's an allegation! And seen as attacking the Mother. For a position statement you would describe situations and behaviours and let the court draw their own conclusions.
Think about it like going to the Doctors. Doctors don't like it if you go in and say - I have a left heart murmur and this is causing palpitations (if you've never been diagnosed previously) - because that is self diagnosing and you're not the Doctor. You go in and you describe your symptoms and let the Doctor, the expert, determine the diagnosis.
Same kind of thing. Courts don't like being given a diagnosis by a parent. They like to make the diagnosis based on the information given.
So you need to keep it child focused - explain the effects on the child of certain actions and behaviours by the Mother for example. Don't make it an allegation against the Mother or it backfires.
