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Recent updates:

• Update: June 2023

  Dear Subscriber:

  Thank you for updating your reference library 2023 edition of Practitioner's Guide to State Intervention in the Family . This entirely revised edition was last published in 2012 under the title Child Welfare Practice in Massachusetts .

  Highlights of the 2023 edition include

  • dedicated chapters on representing parents and representing children;

  • detailed, step-by-step explanations of each and every phase that may arise in state intervention litigation;

  • discussion of medical and mental health treatment for children involved in state intervention cases;

  • a multitude of exhibits to aid in your practice—including checklists, flow charts, sample motions, and more; and

  • a new appendix on the Interstate Compact on the Placement of Children.

  Thank you for your continued support as we at MCLE strive to bring you the latest solutions for your practice.

  Cordially,

  MCLE Press

Table of Contents

Chapter 1 expand

Discovery Planning and Investigation

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Michael J. Coolican, Esq.,
Gregory W. Nye, Esq.,

Checklist 1.1

- Creating a Discovery Plan Buy Form

Checklist 1.2

- Fact-Gathering Stage of Litigation Buy Form

Checklist 1.3

- Types of Formal Discovery in Civil Litigation Buy Form

Exhibit 1A

- Sample Discovery Budget Buy Form

Chapter 2 expand

Preservation and Spoliation of Evidence

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Rhonda J. Tobin, Esq., Robinson+Cole LLP
Jeffrey J. White, Esq., Robinson+Cole LLP

Exhibit 2A

- Sample Documents for a Client Pertaining to a Litigation Hold Buy Form

Exhibit 2B

- Sample Litigation Hold Letter Sent to Opposing Counsel Buy Form

Chapter 3 expand

Scope of Discovery

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Hon. Rupal Shah Palanki, Connecticut Superior Court

Chapter 4 expand

Expert Discovery, Expert Testimony, and Trial Considerations

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Elizabeth A. Alquist, Esq., Day Pitney LLP
David J. Elliott, Esq.,

Checklist 4.1

- Outline for Expert Deposition: Products Liability Case Buy Form

Chapter 5 expand

Protecting Confidential Information

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Drew J. Cunningham, Esq., Carmody Torrance Sandak & Hennessey LLP
Todd R. Michaelis, Esq., Carmody Torrance Sandak & Hennessy LLP
Ann H. Rubin, Esq., Carmody Torrance Sandak & Hennessy LLP

Exhibit 5A

- Annotated Protective Order Template Buy Form

Exhibit 5B

- Motion for Stipulated Protective Order Buy Form

Exhibit 5C

- Stipulated Protective Order Buy Form

Exhibit 5D

- Motion to Seal (State Superior Court) Buy Form

Exhibit 5E

- Memorandum in Support of Motion to Seal Buy Form

Exhibit 5F

- Motion to Seal (Federal District Court) Buy Form

Chapter 6 expand

Interrogatories

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Tanya A. Bovee, Esq., Jackson Lewis LLP
Sally Welch St. Onge, Esq., Jackson Lewis LLP

Exhibit 6A

- Form 201: Plaintiff’s Interrogatories Buy Form

Exhibit 6B

- Form 202: Defendant’s Interrogatories Buy Form

Exhibit 6C

- Form 203: Plaintiff’s Interrogatories—Premises Liability Cases Buy Form

Exhibit 6D

- Form 208: Defendant’s Supplemental Interrogatories—Workers’ Compensation Benefits—No Intervening Plaintiff Buy Form

Exhibit 6E

- Form 210: Defendant’s Interrogatories—Workers’ Compensation Benefits—Intervening Plaintiff Buy Form

Exhibit 6F

- Form 212: Defendant’s Interrogatories—Loss of Consortium Buy Form

Exhibit 6G

- Form 213: Plaintiff’s Interrogatories—Uninsured/Underinsured Motorist Cases Buy Form

Exhibit 6H

- Form 214: Defendant’s Interrogatories—Uninsured/Underinsured Motorist Cases Buy Form

Chapter 7 expand

Requests for Production, Inspection, and Examination

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James A. Budinetz, Esq., McElroy, Deutsch, Mulvaney, & Carpenter LLP
Steven Lapp, Esq., McElroy Deutsch Mulvaney Carpenter LLP
Peter J. Zarella, Esq., McElroy Deutsch Mulvaney Carpenter LLP

Exhibit 7A

- Plaintiff’s Requests for Production (Form 204) Buy Form

Exhibit 7B

- Defendant’s Requests for Production (Form 205) Buy Form

Exhibit 7C

- Plaintiff’s First Request for Production of Documents Buy Form

Exhibit 7D

- Defendant’s Responses and Objections to Plaintiff’s Requests for Production of Documents Buy Form

Exhibit 7E

- Discovery and Deposition Dispute Order Buy Form

Exhibit 7F

- Request for Adjudication of Discovery or Deposition Dispute Under Statewide Standing Order (Form JD-CV-119) Buy Form

Chapter 8 expand

Physical and Mental Health Examinations and Protected Health Information

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Joseph B. Burns, Esq., Crumbie Law Group LLC

Chapter 9 expand

Admission of Facts and Execution of Writings

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Barry J. Waters, Esq., Murtha Cullina LLP

Exhibit 9A

- Sample Notice of Service of Requests for Admission Buy Form

Exhibit 9B

- Sample Requests for Admissions Buy Form

Exhibit 9C

- Sample Responses to Requests for Admissions Buy Form

Exhibit 9D

- Sample Motion to Determine Sufficiency of Responses and to Deem Matters Admitted Buy Form

Exhibit 9E

- Sample Motion to Deem Requests for Admissions Admitted Buy Form

Exhibit 9F

- Sample Motion to Withdraw and Amend Responses Buy Form

Exhibit 9G

- Bibliography Buy Form

Chapter 10 expand

Depositions

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Moy N. Ogilvie, Esq., McCarter & English LLP
Tara A. Sheldon, Esq., McCarter & English LLP

Exhibit 10A

- Sample Notice of Deposition Buy Form

Exhibit 10B

- Sample Motion for Commission Buy Form

Exhibit 10C

- Sample Motion to Quash Buy Form

Chapter 11 expand

Other Discovery Rules and Devices

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Dominic Fulco, III, Esq., Reid and Riege PC
Agnes Romanowska, Esq., Reid and Riege, PC

Exhibit 11A

- Sample Motion for Prejudgment Disclosure of Assets Buy Form

Exhibit 11B

- Sample Application for Order Authorizing the Issuance of a Subpoena Duces Tecum Buy Form

Exhibit 11C

- Sample Motion for Appointment of Discovery Special Master, Pendente Lite Buy Form

Exhibit 11D

- Sample Order Regarding Discovery Special Master and Setting Procedures Buy Form

Exhibit 11E

- Sample Stipulation re: Referee for Discovery Disputes Buy Form

Chapter 12 expand

Motions for Orders of Compliance

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Andrew M. Zeitlin, Esq., Shipman & Goodwin LLP

Exhibit 12A

- Defendants’ Motion to Compel Production of Medical Records Buy Form

Exhibit 12B

- Defendant’s Motion to Compel Plaintiff’s Signature on Authorization Forms Required to Obtain Plaintiff’s Updated Medical Records Buy Form

Exhibit 12C

- Plaintiff’s Motion to Compel and for Sanctions Buy Form

Exhibit 12D

- Motion for Order of Compliance Buy Form

Exhibit 12E

- Objection to Motion to Compel Buy Form

Exhibit 12F

- Defendants’ Objection to Motion to Compel Production Buy Form

Exhibit 12G

- Affidavit in Support of Defendant’s Objection to Motion to Compel Discovery Buy Form

Exhibit 12H

- Discovery and Deposition Dispute Order Buy Form

Exhibit 12I

- Request for Adjudication of Discovery or Deposition Dispute (Form JD-CV-119) Buy Form

Chapter 13 expand

Discovery of Electronically Stored Information

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David A. Reif, Esq.,
Zane C. Riester, Esq.,
Alex A. Toribio, Esq.,
Makenzie Windfelder, Esq.,

Exhibit 13A

- Electronic Discovery Reference Model Buy Form

Exhibit 13B

- Sample Electronic Discovery Outline for Preparing or Deposing a Business Witness Buy Form

Exhibit 13C

- Sample Questionnaire for Interviewing Client Technology Personnel Buy Form

Exhibit 13D

- Sample Notices (Formal and Basic) Buy Form

Exhibit 13E

- Sample Preservation Letter Buy Form

Exhibit 13F

- Model Order Regarding Preservation Buy Form

Chapter 14 expand

Obtaining Information from Government Sources: FOIA

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Michael D. Blanchard, Esq., Morgan, Lewis & Bockius LLP
Christopher M. Wasil, Esq., Morgan, Lewis & Bockius LLP

Chapter 15 expand

Using the Internet in Discovery and Investigation

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Fatima Lahnin, Esq., Carmody Torrance Sandak & Hennessey LLP

Editor(s)

Author(s)