IN THE CIRCUIT COURT OF CARROLL COUNTY, ARKANSAS
JUVENILE DIVISION
ARKANSAS DEPARTMENT
OF HUMAN SERVICESPLAINTIFF
vs. No. JV 2010-84 ED
______
(Mother)
______
(Father)
______, a minor child
DOB 11/22/10DEFENDANT(S)
PETITION FOR SERVICES
COMESNOW______, husband and wife, and state the following:
1. They are the legal parents of David ____ an infant child currently in the legal and physical custody of the Department of Human Services.
2. ______is a disabled person, who receives disability benefits from the Social Security Administration for mild developmental disabilities, or, as designated by the listed impairment, Mental Retardation.
3. ______is therefore in the category of persons protected by Title II of theAmericans with Disabilities Act, 42 U.S.C. 12101-12213. She is entitled to reasonable accommodation of her disability in the provision of state services.
4. The parents in this case have been provided generic reunification services, which have not been related to the specific disability of ______. In order to accommodate the disability of ______, and in order to facilitate the reunification of ______with his parents, petitioners request the following targeted actions and services:
(a) Coordination with and referral to The Department of Human Services Developmental Disabilities Division, more specifically, the part C early intervention program, which provides services for parents and children with developmental disabilities, and programs to enhance the capabilities of children and families with developmental disabilities.
(b) DCFS should be ordered and directed to contract with the Carroll County Learning Center in order to provide qualified behavior and learningspecialists, who are trained in working with the mentally retarded, to assist the family in obtaining parenting skills, and to identify and provide the family with relevant learning materials directed to persons with cognitive disabilities.
(c) DCFS should identify resources for day care assistance with David during the day when Mr. ____ is at work, and/or in the initial stages of home visits prior to a temporary home placement.
(d) DCFS should promptly institute in home visitation and educational services conducted in the most homelike atmosphere practicable.
(f) DCFS should make inquiry and report to the Court on the availability of Medicaid Waiver Services to provide care for family members in the home.
(g) DCFS, in conjunction with the Developmental Disability Section of the Department of Human Services, should provide targeted, intensive, in-home services for 90 days, including training and assessment in the following areas:
l. Continuation of the family therapy for ______
2. Individual therapy for ______to address her fear and resentment over the
removalof her child.
3. Communication skills
4. Anger Management for ______
5. Crisis intervention services
6. Fiscal and home management skills as needed.
7. Homemaker services with emphasis on the control of allergens.
8. Smoking cessation services if requested by the parents.
9. The development of a permanent safety plan
10. Reading infant cues and learning signals.
11. Cognitive and behavioral training as necessary.
12. Responding to emergencies, and first aid.
13. Age appropriate CPR
14. Provision of home safety supplies, and emergency breathing apparatus.
15. Menu Planning
16. Simple and instructive texts or videos relating to disciplinary strategies, home safety hazards, recognizing illness, infant stimulation and responsiveness and emergencies.
17. Provision of air purifiers in the residence if needed.
WHEREFORE, petitioners pray for the services requested above, and for any and all additional services to accommodate the disability of ______, and to accomplish the stated goal of reunification of the child with his parents.
______
MARGARET REGER,
Attorney for ______
Legal Aid of Arkansas
816 North Main Street
Harrison, Arkansas 72601
Telephone: (870) 741-2454, or
1-800-967-9224, Ex. 5302
Facsimile: (870) 741-4255
CERTIFICATE OF SERVICE
On this 3rd day of November ,2011, I delivered the foregoing pleading in open court to the following persons:
- Tammy Mullins, AAL for David Spall
- Robert Depper, Attorney for Arkansas Department of Human Services