argued in court files today that his estranged wife,

, is an "emotionally disturbed individual focused on her own needs rather than the needs of Kiara or my missing Kyron."

Kaine Horman, who is fighting Terri Horman's push to have time with her daughter Kiara, says he's concerned that any contact Terri Horman has with Kiara will be detrimental, and argues that removing their daughter from her mother has "hugely benefited'' the toddler.

He suggests that Terri Horman has an undiagnosed personality disorder or some type of emotional disturbance.

He wonders if Kiara witnessed "some unimaginable act of horror," on June 4 when

, then 7, disappeared from Skyline School. He says Terri Horman's behavior after Kyron's disappearance -- failing polygraph tests, changing stories while displaying no emotions -- convinced him she's responsible.

Read the court documents

Documents filed by Kaine Horman in Multnomah County Circuit Court Monday:

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(warning, graphic sexual contact).

"I believe that Respondent has harmed or secreted Kyron,'' Kaine Horman wrote in an affidavit filed today.''

He included as exhibits back-and-forth text messages between Terri Horman and his high school friend, Michael Cook, in which his estranged wife wonders if she's "going to get any ever again....," and sent photos of her breast and of her masturbating.

"It is deeply concerning that while Kyron was missing and the media was trying to assist us, Respondent was engaged in such behavior,'' Kaine Horman wrote in his affidavit.

Kaine Horman said the text messages continued after she was forced out of their home on Northwest Sheltered Nook Road.

"It causes great pain to wonder if Kiara was with respondent on June 4, 2010 and witnessed some unimaginable act of horror," Kaine Horman wrote. "Until respondent begins answering questions about the events of June 4, 2010, I cannot support any contact between her and Kiara, even if supervised."

Terri Horman has been the focal point of investigators since her stepson disappeared from the school. His stepmom had driven him to school early that day for a science fair. Although he never made it to his classroom, he wasn't reported missing until that afternoon when he didn't return home by school bus.

No arrests have been made.

Kaine Horman moved out of their home on June 26 after learning from investigators that a landscaper told police he had been approached by Terri Horman about six months before Kyron's disappearance to kill her husband in an alleged murder-for-hire plot. On June 28, Kaine Horman filed for a restraining order against his wife, restricting her from any parenting time with their daughter , and filed for divorce.

Terri Horman's lawyer, Peter Bunch, has argued that Terri Horman is Kiara's primary caregiver, and that Kiara needs to see her mother, even in supervised visits.

Kaine Horman challenges Bunch's assessment.

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He argues that he is Kiara's primary caregiver. He says he worked at home 3 to 5 days a week during their marriage, and would be home and present with both children most afternoons and evenings, unless traveling for business.

Kaine Horman cited Terri Horman's "historical problems with the abuse of alcohol," which he argues impaired her functioning since Kiara's birth.

He said Terri Horman's conviction in 2005 for driving while under the influence of alcohol was not an isolated incident. He said Terri Horman's depression and alcoholism impaired how she cared for their daughter.

"It was common for respondent to be visibly impaired from alcohol, slurring speech, staggering gait, etc., several nights a week," he said. He writes in the affidavit that Terri Horman passed out on the couch after drinking heavily at night, and he'd find Kiara up past midnight playing or watching TV until he intervened.

He cites Terri Horman's focus as being primarily on her own appearance and needs without consideration of others', noting that she'd leave Kiara in her gym daycare for hours while she worked out, and even flirted with others at the gym. He called her time spent on social networking sites "unhealthy."

"She spent more time on the computer than caring for children," Kaine Horman said.

Kaine Horman said he asked Terri Horman numerous times where she was on June 4, and what she knew, and she dodged his questions.

In text messages from June 30 through July 6 to Cook, Terri Horman referred to her criminal defense lawyer Stephen Houze as "Steve aka lawyer extrordainairre'' (sic). On July 3, she texted about the use of a "clean phone" to avoid monitoring by law enforcement, and on July 6, went to Cook's house, later telling him to lie for her or she would "get in trouble,'' Kaine Horman says in the affidavit.

Kaine Horman pleads with Terri Horman to begin cooperating with law enforcement. "I want Respondent to tell the truth. I want Respondent to provide information to investigators that may lead to Kyron's location.''

Kaine Horman says he's learned from law enforcement officials that more than one circuit judge had found probable cause exists to implicate his estranged wife in Kyron's disappearance and in a murder-for-hire plot.

"I believe that Respondent is severely emotionally disturbed and unfit to parent Kiara. Her actions are horrifying and unexplainable,'' Kaine Horman wrote. "Kiara's physical and emotional safety are now at extreme risk.''

A Multnomah County judge has set aside a week in January, starting Jan. 4 in which the two sides will argue whether to allow Terri Horman to see her daughter, and a pending motion by Kaine Horman seeking to determine the source of the money paid for her to retain Houze, a high-profile criminal defense attorney.

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