I would suggest that you say the allegations have been raised to frustrate contact with the children (ideally use their names)..
When it comes to allegations of controlling and coercive behaviour my solicitor was adamant that we shouldn't use any emotive, inflammatory or negative language as this can come across (even unintentionally) aggressive and controlling which is a picture you don't want to paint nor place any doubt in the courts mind. Therefore if everything is calm, measured and considered, it will be the opposite to what the judge is expecting when reading her allegations and at future hearings speaking and listening to you. Including any hearings to deal with child contact.
@daddy-up with statement gonna be asked do I accept the order how would I then word it..I am willing for the to be mutual undertakings with no admission no findings..if get rejected then state I contest all allegations and my reasons why ?
You need to reject in the first instance in order to get to a final hearing if you are confident of your position..
Accepting an undertaking is a last resort but after final hearing..
I think on this thread and your other one I think you've had some suggestions on how to word things..
Also remember as you are contentesting and your children are young and you have no 3rd party to facilitate, it is unlikely you will get any contact with the kids until the NMO final hearing has been done. Many suggest asking for interim contact but this only works if ex is willing to support, courts will not make her considering the allegations she has put forward.
Therefore remember that things may get emotional so be prepared and remain calm.
Challenging a NMO can be complex especially without legal advice.
There is a lot of advice online as to how to respond and prepare to do so.
All the best.
@daddy-yep thank you for your advice along way statement all prepared now roll on Monday nerve racking but all the help received has been great help
That's great. Good Luck