I'm not sure what you are requesting. You have adequate cause to withhold the daughter from the mother based on CPS instructions (and, it sounds like, common sense). Find out if CPS has hearings set.
Either way, consider filing a motion in family court for at least temporary sole physical custody until mother gets her facilities adequate, gets her head straight, and perhaps has a mental evaluation. If you don't know how to do this, and do not wish to use the self-help forms, you should consult with, and hire competent family law counsel.
Answered on Oct 20th, 2014 at 9:26 AM