DOCKET NO:

______

:

IN RE AR : SUPERIOR COURT

IN RE P C :

IN RE JC : JUVENILE MATTERS AT NEW

IN RE AC : BRITAIN

:

: AUGUST 3, 2001

______:

MOTION FOR CONTACT WITH CLIENTS

IN THEIR PLACE OF RESIDENCE

Pursuant to the American Bar Association=s Standards of Practice for Lawyers Representing Children, and pursuant to the terms of her contract with Connecticut Superior Court, Juvenile Matters, for representing children, the Attorney for the children in the above-captioned matter, Martha Stone, Esq., hereby moves this court for contact with the children in their place of residence.

In support of this motion, the counsel for the children avers the following:

1. On June 1, 2001, Judge Swienton of the Hartford Superior Court appointed Martha Stone to represent A R, J C, PC and A C (“the children”) in this matter.

2. Attorney Stone has met with the children in their mother’s office at in Hartford. However, the mother (S R) has denied Attorney Stone access to the children in their home, and to the home in general. Ms. Rhas also refused to disclose the home address of the children.

3. In order to fulfill her duties under Section 1C of the ABA Standards of Practice, and under Section 7 of her contract with the Superior Court to represent children (copies of both documents are attached to this motion), Attorney Stone needs to be able to observe the home environment in which the children are living, and to observe the children in the home setting. Such access is critical to adequately representing the children in this matter, where the children’s ongoing safety and well being is a central issue.

4. For the foregoing reasons, Attorney Stone requests that the court order Ms. R to allow Attorney Stone to meet with the children in the family home, and to have ongoing access to the children at the home in order to meet with them there a minimum of once per month.

WHEREFORE, the attorney for the children respectfully requests that this court grant the motion for access to the children in their home.

Respectfully Submitted,

BY:______

Martha Stone

Center for Children’s Advocacy, Inc.

University of Connecticut School of Law 65 Elizabeth Street

Hartford, CT 06105

Juris # 61506

(860) 570-5327

Attorney for Respondent Children

O R D E R

The above motion 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 S R, Pro Se, (ADDRESS), Hartford, CT, and Deanna Levine, Assistant Attorney General, MacKenzie Hall, 110 Sherman Street, Hartford, CT 06105, this day of August, 2001.

______

Martha Stone

-1-