Product Description

Recent updates:

• Update: September 2025

  Dear Subscriber:

  Thank you for updating your library with the 2025 edition of A Practical Guide to Discovery and Depositions in Rhode Island offering the latest answers to your practice challenges. Highlights from the most recent developments include

  • pending amendments to Rhode Island court rules that will affect deposition practice as well as electronic filing and remote communications procedures;

  • the scope of records protection under the Access to Public Records Act and the Driver's Privacy Protection Act;

  • guidance on the use of artificial intelligence in litigation practice;

  • case law on the use of social media accounts to obtain information on a litigation opponent;

  • a Rhode Island Supreme Court case commenting on the authenticity of text messages and emails;

  • the discoverability of a surveillance video held by the opposing party;

  • the use of requests for admissions to establish facts and narrow the issues for trial;

  • the application of the Uniform Interstate Deposition and Discovery Act (UIDDA);

  • the obligation to preserve electronically stored information (ESI) and the use of technology-assisted review (TAR) to search ESI for relevant materials;

  • remedies for spoliation and related types of discovery misconduct; and

  • the use of subpoenas to obtain evidence from third parties.

  We trust you will find the 2025 edition of A Practical Guide to Discovery and Depositions in Rhode Island a valuable resource, as we at MCLE continue our efforts to bring you the latest solutions to the issues you face in your practice.

  Cordially,

  MCLE Press

Table of Contents

Chapter 1 expand

Acknowledgments of Parentage

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Pauline Quirion, Esq., Greater Boston Legal Services

EXHIBIT 1A

- DSS Parental Responsibility Form Buy Form

EXHIBIT 1B

- Acknowledgment of Paternity Buy Form

EXHIBIT 1C

- Affidavit of Denial of Paternity Buy Form

EXHIBIT 1D

- Complaint to Rescind Paternity Acknowledgment Buy Form

Chapter 2 expand

Chapter 209C Basics—From Commencement of an Action to Judgment

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Pauline Quirion, Esq., Greater Boston Legal Services

EXHIBIT 2A

- Complaint for Custody-Support-Parenting Time Buy Form

EXHIBIT 2B

- Complaint to Establish Paternity Buy Form

EXHIBIT 2C

- Public Assistance Affidavit Buy Form

EXHIBIT 2D

- Motion for Release of Birth Certificate Buy Form

EXHIBIT 2E

- Completed Sample Domestic Relations Summons on Complaint for Paternity Buy Form

EXHIBIT 2F

- Long-Arm Jurisdiction Grounds Buy Form

EXHIBIT 2G

- Motion for Mother’s Genetic Marker Testing Buy Form

EXHIBIT 2H

- Motion for Genetic Marker Testing by Putative Father Buy Form

EXHIBIT 2I

- Motion for Custody and Child Support Buy Form

EXHIBIT 2J

- Model Proposed Order for Child Support and Custody Buy Form

EXHIBIT 2K

- Motion for Parenting Time Buy Form

EXHIBIT 2L

- Defendant’s Answer to Complaint to Establish Paternity Buy Form

EXHIBIT 2M

- Sample Pretrial Memorandum Buy Form

Chapter 3 expand

Naming Nonmarital Children: Birth Certificates and Name Change Petitions

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Christine M. Durkin, Esq., Northeastern University School of Law

EXHIBIT 3A

- Voluntary Acknowledgment of Parentage Buy Form

EXHIBIT 3B

- Affidavit of Nonpaternity Buy Form

EXHIBIT 3C

- Certificate of Name Change Buy Form

EXHIBIT 3D

- Sample Motion to Waive Notice of Name Change Proceeding Buy Form

EXHIBIT 3E

- Petition for Change of Name Buy Form

EXHIBIT 3F

- Affidavit for Care and Custody Buy Form

EXHIBIT 3G

- CP2 Request for Information Form Buy Form

Chapter 4 expand

Genetic Marker Testing

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Laura Gahn, Ph.D, IDENTIGENE
George C. Maha, Esq., Laboratory Corp. of America Holdings (LabCorp) Laboratory Corp. of America Holdi

Chapter 5 expand

Requesting, Using, and Challenging Parentage Testing Results

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Patrick M. Finn, Esq., Department of Revenue, Child Support Enforcement, Commonwealth of Massachusetts

EXHIBIT 5A

- Motion for Genetic Marker Testing Buy Form

Chapter 6 expand

Equity Actions by Putative Fathers Who Lack Standing Under Chapter 209C and Challenges to Paternity of Children Born During a Marriage

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Pauline Quirion, Esq., Greater Boston Legal Services

EXHIBIT 6A

- Equity Complaint to Establish Paternity Pursuant to G.L. c. 215, § 6 Buy Form

EXHIBIT 6B

- Emergency Motion for Speedy Preliminary Hearing Buy Form

EXHIBIT 6C

- Defendant’s Motion for a Guardian Ad Litem Buy Form

EXHIBIT 6D

- Affidavit in Opposition to Genetic Testing Motion in Divorce Case Buy Form

EXHIBIT 6E

- Opposition to Genetic Testing Motion in Divorce Case Buy Form

EXHIBIT 6F

- Model Interlocutory Petition for Appeal of a Genetic Testing Order in a Divorce Action Buy Form

EXHIBIT 6G

- Memorandum to Overturn Genetic Testing Order in a Divorce Case Buy Form

Chapter 7 expand

Equity Actions Filed by De Facto Parents

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Mary L. Bonauto, Esq., GLBTQ Legal Advocates and Defenders
Patience Crozier, Esq., GLBTQ Legal Advocates and Defenders

EXHIBIT 7A

- Sample De Facto Parent Complaint Buy Form

Chapter 8 expand

Transgender Parents and Children Born Outside of Marriage

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Jennifer L. Levi, Esq., Western New England University School of Law

Chapter 9 expand

Custody, Visitation, and Removal Issues Related to Children of Unmarried Parents

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Michelle M. Ahern, Esq., Taylor, Ganson & Perrin LLP
Jaime B. Margolis, Esq., Community Legal Aid/Hampden County
Patricia A. Saint James, Esq., Tarlow, Breed, Hart & Rodgers, PC

Checklist 9.1

- Chapter 209C Custody Checklist Buy Form

Checklist 9.2

- Checklist for Bringing a Contempt Complaint Buy Form

Checklist 9.3

- Checklist for Defending Against a Contempt Complaint Buy Form

Checklist 9.4

- Checklist for Bringing a Guardianship Petition Buy Form

Checklist 9.5

- Checklist for Opposing a Guardianship Petition Buy Form

Checklist 9.6

- Checklist for Removal of Minor Child from the Commonwealth Buy Form

EXHIBIT 9A

- Complaint to Establish Paternity Buy Form

EXHIBIT 9B

- Complaint for Custody-Support-Parenting Time Pursuant to G.L. c. 209C Buy Form

EXHIBIT 9C

- Motion for Temporary Order of Custody of Minor Child Buy Form

EXHIBIT 9D

- Motion for Temporary Order of Visitation Buy Form

EXHIBIT 9E

- Proposed Temporary Order Buy Form

EXHIBIT 9F

- Complaint for Contempt Buy Form

EXHIBIT 9G

- Contempt Summons Buy Form

EXHIBIT 9H

- Answer to Contempt Complaint Buy Form

EXHIBIT 9I

- Complaint for Modification Buy Form

EXHIBIT 9J

- Notarized and Verified Consent or Nomination by Minor Buy Form

EXHIBIT 9K

- Petition for Guardianship Buy Form

EXHIBIT 9L

- Bond for Guardianship Buy Form

EXHIBIT 9M

- Notarized Waiver and Consent to Petition for Guardianship of Minor Buy Form

EXHIBIT 9N

- Probate and Family Court Standing Order 4-09: Notice in Guardianship of Minors Matters Buy Form

EXHIBIT 9O

- Motion for Appointment of Temporary Guardian for a Minor Buy Form

EXHIBIT 9P

- Affidavit in Support of Emergency Temporary Guardian Buy Form

EXHIBIT 9Q

- Order Appointing Temporary Guardianship of Minor Buy Form

EXHIBIT 9R

- Rule 29B Affidavit Buy Form

EXHIBIT 9S

- Motion for Removal of Temporary Guardian of Minor Buy Form

EXHIBIT 9T

- Petition for Removal of Guardian of Minor Pursuant to G.L. c. 190B, § 5-212 Buy Form

EXHIBIT 9U

- Request for Counsel Buy Form

EXHIBIT 9V

- Petition for Grandparent(s) Visitation Buy Form

EXHIBIT 9W

- Answer to Complaint for Grandparent Visitation Buy Form

EXHIBIT 9X

- Agreement for Removal of Minor Child from the Commonwealth Buy Form

EXHIBIT 9Y

- Complaint for Authorization to Remove Minor Child from the Commonwealth Buy Form

EXHIBIT 9Z

- Affidavit in Support of Removal of Minor Child from the Commonwealth Buy Form

Chapter 10 expand

Domestic Violence Issues

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Sandra E. Lundy, Esq., Lundy Legal LLC

EXHIBIT 10A

- Sample G.L. c. 209A, § 11 Petition Relative to Domesticated Animal(s) Buy Form

EXHIBIT 10B

- Motion for Ex Parte Domestic Relations Protective Order Buy Form

EXHIBIT 10C

- Affidavit in Support of Protective Order Buy Form

EXHIBIT 10D

- Address Confidentiality Program Buy Form

EXHIBIT 10E

- Motion for Impoundment and Affidavit Buy Form

EXHIBIT 10F

- Motion for Order Excusing Service of Protective Order Buy Form

EXHIBIT 10G

- Personal Safety Plan for Victims of Domestic Violence Buy Form

EXHIBIT 10H

- Sample Arguments Against Mutual Restraining Orders Buy Form

EXHIBIT 10I

- Affidavit for Filing Out-of-State Protective Order Buy Form

EXHIBIT 10J

- Model Proposed Findings and Rulings Buy Form

Chapter 11 expand

Trial and Evidentiary Issues in Proving Paternity

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Pauline Quirion, Esq., Greater Boston Legal Services
Mark T. Smith, Esq., Atwood & Cherny, PC

EXHIBIT 11A

- Plaintiff’s Requests for Admissions Buy Form

EXHIBIT 11B

- Plaintiff’s Trial Chalk of Retroactive Support Buy Form

EXHIBIT 11C

- Sample Proposed Judgment on Complaint to Establish Paternity Buy Form

EXHIBIT 11D

- Sample Proposed Findings of Fact and Rulings of Law Buy Form

Chapter 12 expand

Postjudgment Relief from Paternity Adjudications and Modifications

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Pauline Quirion, Esq., Greater Boston Legal Services

EXHIBIT 12A

- G.L. c. 209C, § 11—Text of Statute and Amendments Buy Form

EXHIBIT 12B

- G.L. c. 209C, § 8—Text of Statute and Amendments Buy Form

EXHIBIT 12C

- Motion to Strike Genetic Testing Report and All Reference to Report Buy Form

EXHIBIT 12D

- Motion for Relief from Judgment Pursuant to Rule 60(b)(1)–(3) Buy Form

EXHIBIT 12E

- Affidavit in Support of Motion for Relief from Judgment Buy Form

EXHIBIT 12F

- Sample Opposition Where Father Has No Relationship with Child Buy Form

EXHIBIT 12G

- Affidavit to Oppose Relief from Judgment Buy Form

EXHIBIT 12H

- Sample Opposition Where Father Has Relationship with Child Buy Form

Chapter 13 expand

Child Support

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Kelly A. Leighton, Esq., Barnes & Leighton
Christina Paradiso, Esq., Community Legal Aid

Chapter 14 expand

Retroactive Support Awards, Attorney Fees, and Alternative Methods for Payment of Support

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Mary H. Schmidt, Esq., Verrill Dana LLP
Kristin Youkana, Esq., Stryker

Checklist 14.1

- Paternity—Retroactive Child Support Buy Form

EXHIBIT 14A

- Sample Proposed Findings and Judgment Buy Form

EXHIBIT 14B

- Sample Proposed Findings for Litigants Seeking Retroactive Relief Buy Form

EXHIBIT 14C

- Sample Motion for Allowance of Counsel Fees Buy Form

EXHIBIT 14D

- Sample Affidavit of Counsel Buy Form

EXHIBIT 14E

- Sample Certificate of Attorney Buy Form

Chapter 15 expand

Paternity Issues in the Juvenile Court Context

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EXHIBIT 15A

- Complaint to Establish Paternity and/or for an Order of Child Support Buy Form

EXHIBIT 15B

- Affidavit Disclosing Care or Custody Proceedings Buy Form

EXHIBIT 15C

- Notice of Judgment Establishing or Not Establishing Paternity Buy Form

EXHIBIT 15D

- Affidavit of Nonpaternity Buy Form

Chapter 16 expand

Inheritance and Support Issues for a Disinherited Child Born Outside of Marriage

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Lisa M. Cukier, Esq., Rubin Rudman LLP
Katie M. Dalton, Esq., Bowditch & Dewey LLP
Bryce J. Helfer, Esq., Hemenway & Barnes LLP

Chapter 17 expand

Selected Appellate Issues in Paternity-Related Cases

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Patricia A. DeJuneas, Esq., Sibbison, DeJuneau & Allen LLP

Appendix

Summaries of Significant Chapter 209C and Parentage-Related Cases

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Pauline Quirion, Esq., Greater Boston Legal Services

Editor(s)

Judicial Commentator(s)

Author(s)