Ex Parte Motion for Copy of Transcripts NEW

							DOCKET NO.
______________________________
                              :               SUPERIOR COURT
                              :
IN RE ________                :               JUVENILE MATTERS AT HARTFORD
                              :
______________________________:               MARCH X, 200X


                 EX PARTE MOTION FOR COPY OF TRANSCRIPT

       Pursuant to Conn. Gen. Stat. § 46b-124 and Conn. Practice Book § 32a-7, the

attorney for the child, ___________, respectfully requests this Court provide a copy of the

transcript of the initial termination of parental rights plea hearing (“TPR plea hearing”) held

in this case on January X, 200X. In support of this motion, the child asserts the following:

       1.      ________ was placed in DCF care pursuant to an Order of Temporary

Custody on August X, 200X due to her parent’s substance abuse and unaddressed mental

health issues. She was committed to the Department on August X, 200X, and has remained

in its care since that date. On April X, 200X, _______’s mother, ___________, consented

to a termination of parental rights. On November X, 200X, this Court approved a

permanency plan of termination of parental rights and adoption.

       2.      For purposes of preparing for a termination of parental rights trial on April

X, 200X regarding the respondent father, ________, it is imperative for the child’s




ORAL ARGUMENT NOT REQUESTED

TESTIMONY NOT REQUIRED
                                             -2-


attorney to inspect the transcript of the TPR plea hearing held on January X, 200X, in that

the father had indicated—to the best of counsel’s recollection—that he was ambivalent

about whether to oppose the termination of parental rights.

       WHEREFORE, undersigned attorney for _______ respectfully requests this Court

to provide the child’s attorney with a copy of the TPR plea hearing transcript held on

January X, 200X. Undersigned counsel has made efforts to contact attorneys for the

respondent father and for the Department. Counsel for the Department has stated that he

has no objection to this motion, while the attorney for the father has not yet responded to

our contact efforts.

                                                Respectfully submitted,


                                                __________________________________
                                                Martha Stone
                                                Center for Children’s Advocacy, Inc.
                                                University of Connecticut School of Law
                                                65 Elizabeth Street
                                                Hartford, CT 06105
                                                Juris # 421708
                                                (860) 570-5327
                                                (860) 570-5256 fax

                                                Attorney for ________
                                            -3-


                                        ORDER

       The above Motion for Copy of Transcript having come before this Court for

consideration, it is hereby ordered:

GRANTED/DENIED



                                             ____________________________________
                                             Judge, Superior Court




                              CERTIFICATE OF SERVICE

       This is to certify that a copy of the foregoing has been mailed, postage prepaid to

Assistant Attorney General, MacKenzie Hall, 110 Sherman Street, Hartford, CT 06105, and

Traci Valery, 262 Elm Street, West Haven, CT 06516, this 11th day of March, 2009.



                                             ____________________________________