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

2. 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

3. 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 ed 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

4. 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

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

6. 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

7. 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

8. Amber D. Walden
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