In depth interview with the client, her grandmother, the other maternal relatives. Confront case deficiencies head-on, look for what is missing from the picture as a whole.
Absentee father for a decade, no support of the child including child support payments, no ability for the father to seek family court redress for even visitation beyond what the mother allowed, as his paternity was not established.
Get as much information on the timeline of contacts of the father vs. involvement of the grandmother.
Including declaring loudly to father’s counsel in earshot of the father that there is no way the father would prevail because of my client’s age and position, the facts of the case, and the seminal case Bennett v. Jefferies and that this is a Bennett case and that father’s counsel would be well-advised to re-read that case and advise his client about the state of the law with respect to Bennett hearings etc and that if he wanted to have one we were prepared to show the extent of his decade of absenteeism vs the grandmother being there every day and how he never availed himself of his rights in court before though the relationship was known to him.