ttcycle
Cycling Excusiast
If they really are as bad as you say and you are prepared to let the new employer know that than as Greedo and Norm have said make sure you have all the evidence for that but I'm sure you know this but don't make any assertions ie mental health and make sure that the evidence you provide has been taken up with the employee beforehand as you need to have demonstrated performance management otherwise this would cause you problems down the line if it went to further