-1IN THE JUVENILE COURT OF DEKALB COUNTY

STATE OF GEORGIA

IN THE INTEREST OF: File #:

Children Under 18 Years of Age

______________________________________________________________________________

MOTION FOR DISCOVERY

_______________________________________________________________________
_

COMES NOW, Respondent Father to minor child, and file this his Motion for
Discovery pursuant to O.C.G.A.§§9-11-26 thru 9-11-37. In support of his Motion,
Respondent shows the following:

1.
On or about October 11, 2007, the above minor children came into the care and
custody of Petitioner due to allegations that the mother was incarcerated, lacked stable
housing and employment.

2.
On January 27, 2010, a hearing is set on Petitioner’s Petition to End Reunification
Services (hereinafter, “Petition”) as to the mother and Respondent Father.

3.
Respondent asserts that his request for the following documents are essential to
his ability to properly defend himself against the allegations made in the Petition:

a. Copies of all contact sheets, including Form 452, describing Petitioner’s

in-person, telephone, and written communications with this case;

b. Documentations of any and all services and referrals for services made by
Petitioner for Respondent Father;

c. Documentations of any and all efforts made to place the minor child,
, with relatives;

d. Copies of all Safety Plans, Safety Resource Plans, summary reports,

Family Assessment that are directed to Respondent Father;

e. All visitation plans and any documentations regarding scheduled visits

between Respondent and his minor son;

f. The 30-Day Case Plan for Reunification stating all goals and objectives,
and visitation schedule as to Respondent Father;
 g. All audio and video recordings and respective written reports and/or
transcripts that involves Respondent and allegations of sexual
misconduct as the minor children;

h. All medical, forensic reports, or otherwise related to allegations of sexual

misconduct as to Respondent Father and the minor children;

i. All statements, police and supplemental reports related to allegations of

sexual misconduct as to Respondent Father and the minor children;

j. Any and all transcript(s), orders and decisions made in previous hearings
or trial(s) as to Respondent Father;

k. All names of potential and actual witnesses expected to testify, a statement

indicating as to what each witness testimony will be; contact information
for each; resume or CV for all expert witnesses, reports,
assessments,
publications, or otherwise that may be relied upon either in preparation for
or during testimony; and

l. Any and all other documents, papers, correspondences, reports,

assessments, or otherwise that is directly or indirectly related to this case
and which may or may not be used by Petitioner, Child Advocate, or other
interested or involved persons.

WHEREFORE, Respondent prays this Honorable Court will:

1. Grant his Motion for Discovery;
2. Set this matter down for a hearing to be heard prior to January 27, 2010; and
 3. Grant any and other relief this Honorable Court deems just and proper.

This ____ day of January, 2010.

Respectfully submitted,

__________________________
Ella A. Hughes
Attorney for Respondent Father
State Bar No: 009147

THE HUGHES GROUP

1230 Peachtree Street, Suite 1900
Atlanta, GA 30309
404.648.5648 (office)
770.369.4705 (mobile)
404.601.7360 (fax)
 CERTIFICATE OF SERVICE
I certify that I have this day served the following parties with a copy of the

Respondent’s Request for Discovery by hand deliver to:

This ____ day of January, 2010

Respectfully submitted,

___________________
Ella A. Hughes
Attorney for Respondent Father
State Bar No: 009147

THE HUGHES GROUP

1230 Peachtree Street, Suite 1900
Atlanta, GA 30309
404.647.5648 (office)
770.369.4705 (mobile)
404.601.7360 (fax)
 IN THE JUVENILE COURT OF DEKALB COUNTY
STATE OF GEORGIA

IN THE INTEREST OF: File #:

Children Under 18 Years of Age

______________________________________________________________________________

RULE NISI
_______________________________________________________________________
_

A Motion for Discovery having been filed by Respondent Father and having been

read and considered by this Court, all parties to this case, including, but not limited to

Petitioner and the Child Advocate are hereby ORDERED to appear before this Court on

the ____ day of ________________, 2009, at ______ o’clock ___.m., Courtroom ____.

SO ORDERED this _____ day of _________________, 2010.

_____________________
Judge,
Dekalb County Juvenile Court

Order presented and prepared by:

_____________________
Ella A. Hughes
Attorney for Respondent Father
State Bar No: 009147