What you wrote seems reasonably good. Ideally you can have a lawyer deal with this but if not, a simple and clear presentations can be effective (the problem with most pro ses is convoluted, confusing, legalistic, and belligerent papers which do not convince the judge and they then assume he/she was paid off by the other side).

You should see if there are legitimate concerns on the other side and perhaps try to work with his wife. That said, the many times he failed to come is important here.