For Parent Attorney Representation in Dependency Matters Best Practices For Parent Attorney Representation in Dependency Matters

Request Documents Ahead of Time Dependency Petition Case Plans GAL (and/or CAA) Reports—By Motion, if necessary CASA Reports Mental health evaluations (your client‘s and the child’s)—By Motion, if necessary Medical records (your client‘s and the child’s)—By Motion, if necessary Request Documents Ahead of Time

Review Documents Case Plans Review proposed Case Plan for errors Review proposed Case Plan for discrepancies Make sure that the goals are narrow and tailored to your client’s particular situation Try to have redundant items deleted Try get the requirement for psychiatric evaluation removed if no real indication of need Orders Review proposed Orders when emailed from the SAAG, by comparing your notes with what has been stated in the Order Review ALL Orders signed by the Judge (in CPRS or in the physical file) Review Documents

Preserve the Record Make objections to testimony and evidence Even if you feel/think it is going to be overruled Specifically state the reason for your objection Make objections to drug screens or mental health evaluations if there is nothing in the Petition Object to continuances (if benefits your client) Make the SAAG read aloud all changes to amended Petitions and Case Plans Whenever possible, consider waiving PC vs. stipulating to the Petition Either way, try to keep the CM on track if the judge asks them to put the Dept’s “reasonable efforts” on the record. Preserve the Record

File Stuff Legitimation (if judge allows) Discovery Motion Custody Modification Judicial Review Guardianship CPRS—Working towards getting electronic filing capabilities. File Stuff

Talk Candidly to Your Client It may seem obvious for me to say to you and/or for you to tell your clients certain things, but better safe than sorry… Tell your client to cease drug use while going through the dependency process. Recommend that they-–at a minimum—be careful about what they post on social media. As CMs “diligently search” for other family members, they are collecting personal information on our clients as well. Ask your clients to keep you posted and let you know ahead of time about FTMs and Panel Reviews. Ask your clients to let you know when things are not going well with visits Advise your client that if they are having a hard time communicating with the CM, to let you know and you can try to be an intermediary. Talk Candidly to Your Client

Try to Develop a Good Rapport with Others Case Managers Child Advocate Attorneys SAAGs Judges’ staff Staff in the Clerk’s office Other parent attorneys Client’s service providers Try to Develop a Good Rapport with Others

Amber D. Walden waldenfamilylaw@gmail.com (404) 220-7243