Despite the things your ex is saying and accusing, it sounds like it would be better not to accuse too much back. I'm not sure the blackmail one would be taken that seriously. If she is the one making the allegations, it might be better just to not make any back and show you're the one who just wants to co parent amicably (and I know that sounds incongruous when she's accused you of abusing your daughter but it kind of shows you as innocent as well and dismissive of the ridiculous allegations).
So what do you have to do before this fact find? Set out responses to her allegations and list your own allegations?
I think using a barrister for the fact find hearing would really help you get past this fact find, as the danger with fact finds is - even if all her allegations are dismissed, Cafcass can then say there is conflict between parents because you also made some against the ex. Then they tend to give the child tothe Mother anyway and recommend minimal (or no time) to Dad. It's a serious business and presumably the main focus is on getting an order for time with your child.
Once an ex has thrown everything at you, and failed, and you get your order, you can move on with your life a bit with your child.
A fact find hearing is a time when it really really helps to have representation as they can go badly wrong if you try to do it yourself - there's a lot involved. It is possible but you need to keep emotion out of it. A Barrister might be able to persuade a judge to dismiss all your ex's allegations (and yes she has to prove them and have evidence but ultimately it's a Judge's opinion on who they believe and some people act well so having a Barrister guide and persuade the Judge is a big help).
That she blackmailed me into giving her more money or I can’t see our daughter, she made me choose between my family and her and my daughter, she said on numerous occasions she’ll never ever stop me seeing our daughter but then has proceeded to stop all contact,
These are more likely to be seen as arguments about breaking up. The others are her allegations against you. It's instinct to want to retaliate with hurling allegations back but that isn't always the best option.
If it's too late to withdraw any allegations on your part I would just list the two along the lines of
1) Mrs Ex informed me I could only see my daughter if I gave her a large sum of money. I am already paying child support at the assessed rate (if that is the case). But that might just be seen as a divorce financial argument even if it's bad she is using the child as leverage - which is common.
2) Mrs Ex wanted me to give up seeing my family if I was to be with her and my daughter. I can't reject my family but do wish to continue to see my daughter.
Do you have evidence to prove either of those allegations? If not, there is no point making them.
For responses to allegations I believe what people usually do (having not had a fact find myself) is list them as per her schedule eg
1) Allegation that I have sexually abused my daughter: This is categorically untrue and fabricated and has caused me severe stress. Mrs Ex was threatening to withold my daughter if I didn't pay her x amount of money (see exhibit (a) attached).
Exhibit (a) would be your evidence that she threatened to withold your daughter unless you do xyz
2) Allegation that I am not my daughter's Father: This is untrue, however to prove this, a DNA test would be needed. (Have you actually had a DNA test?)
How long is the hearing? A day? Two days? Can you afford to use a direct access barrister for the hearing?
