Thank you for your question and for asking for me
have you tried Family mediation at all?
Are you aware that the site charges more for a phone call.
In fact the father would NOT be able to take that approach in mediation - that is why there is a Mediator involved.
In any event the mother must attend a mediation Information and Assessment meeting (MIAM) before an applictaion can be made to the court.
Once this has been done (or mediation has failed) then the mother can apply to the court for an Order stating that the child lives with her and the father cannot remove the child from the care of the mother other than for mutually agreed contact.
This applictaion is made using a Form C100 available here
Please ask if you need further details
Which is why a Court Order will solve the problem
Then what you need is the Order I have outlined above