COURT STATEMENT FOR DOMESTIC ABUSE NEEDED

Hi I am hoping you can help me with a court statement.

My Fiance Dave has been subjected to domestic abuse by his now estranged Mother for his entire life, including violence, coercive control, psychological and financial abuse etc. Since Dave and I got together in March 2020 and moved in together at my home, his Mother has continued to subject him to domestic abuse such as financial abuse (she was Dave's appointee for his benefits as he has Aspergers) too much of a long story for here but she stopped him from having any money which has now been sorted with DWP, turned his family and friends against him by lying that he had hacked her Microsoft account when I have screenshotted proof that she handed the email account over to him (it was shared for years and Dave mainly had the xbox gaming part of the account) and she has also tried to get Microsoft to give her back the account so she can delete it (she's doing this as she knows that one of Dave's number 1 love is his gaming and and he has hundreds of pounds worth of digital games on the account and that due to his aspergers it would make Dave ill at the threat which it has), false allegations to the Police that he has remotely taken over her router/hacker her etc from his supposed customised computer when it's just a normal gaming computer (and although the two allegations were closed as no evidence was provided by her it is showing the two reports on his Police record which also needs to be removed). This is just a brief summary.

So I on Dave's behalf and at his request intend to instruct a Solicitor on legal aid to submit a court application for a non-molestation order to stop his Mum's ongoing abuse and to just leave him alone as his mental and physical health is really suffering because of all this.

So I need help in drafting a court statement about the domestic abuse, for which I would be paying privately for via PPH.