How old is the daughter? The divorce happened 15 years ago so the daughter has to be close to 18? Others have said the judge will immediately question why he waited 10 years to file this contempt claim which is basically your questions here. I would recommend looking for any type of text messages or email conversations where he willfully chose to accommodate your moving further than 60miles away. Him waiting ten years to file the contempt shouldn't require evidence to dismiss any damages he is seeking but it wouldn't hurt to have backup for his willingness in writing.