If someone else is speaking for you it helps. Ridiculous expecting people to agree. He needs to follow Cafcass recommendations (if they are positive for you - if not the barrister needs to argue your case). I hope the barrister does a good job - sometimes they can be low key at lesser hearings but come into their own with cross examination. Do you know if this is supposed to be a final hearing? If not listed as one it might become one.
I think the other thing with a barrister is - be very clear, politely, what you want them to achieve on the day. Eg say - I would like, if possible for this to be the final hearing and an order made. Cafcass have made recommendations and Judge could order that and I'd like us to try for that. No more agreements or negotiations because it's just time wasting and my childrens lives are in limbo and so is mine (yours). He might not commit to that but say well we can try. So saying something like - I'd really like you to try for that - can help. It's ridiculous, if there are now no welfare issues, that an order hasn't been made. (A line you could drop to your barrister for the Judge). They are a funny breed barristers. I found mine very aloof and not easy to talk to - first time. And they expect a lot of respect - even though we're paying them. But he knew his job and pulled the stops out when it came to it.
At that price he should get you a good order on Monday. Hopefully the Judge has decided it's time to stop having hearings on your case and an order made too.
Maybe take a draft order wording with you? Doesn't have to be correct terminology, Just write out exactly what you want in an order and give it to the barrister and say this is the order I'd like to try and achieve on the day and have things finaiised.
So set out the defined times and dates etc
Eg
Child will live with both parents
With Father during term time:
Week 1 9am Wednesday to 9am Friday
Week 2 9am Wednesday to 9am Monday
Child lives with Mother at all other times during term time (ie the other half/days)
And half the school holidays with each parents as follows:
October half term with Father, May half term with Mother, February half term split, keeping to usual week-end schedule with changeover on Wednesday midday, the summer, easter and Christmas holidays split into two clear halves with the half alternating each year - first half with Mother in 2022 and even years and with Father in 2023 and odd years - second half with Father in 2022 and even years and with Mother in 2023 and odd years.
All school holidays to commence at the time school finishes on the last day of term and end at the time school recommences on the first day of the next term.
Neither parent may change the child's school without the consent of both parents in writing (gives a heads up if she's thinking of moving in case you need to put a prohibited steps order in).
Mother will normally retain childrens passports but will release them to Father for any purpose needed, on request, and within 21 days of any booked holiday.
Such further or other times as agreed by the parties in writing.
In the event that the Mother breaches this order, the Children will live with the Father and spend time with the Mother 6 nights a fortnight and half the school holidays.
That last bit is a suspended residence clause. You could try for it - probably unlikely to get it but it might be enough to scare her into agreeing to the rest of the order if your draft is given to her on the day.
