Attorney Center

Motions Bank

ORPC provides sample motions as a resource to our contractors. Please be aware that the motions and briefs posted here may not represent the current state of the law applicable to a specific set of facts. While helpful as a starting point for research on a pending legal issue, motions posted here are statements of the law as perceived by particular attorney in the context of a particular case at some point in the past. They are not a substitute for thorough and independent research in the context of the facts of a pending case.

You can browse the entire list, filter by motion category, or search titles and descriptions.

TitleContentFile TypesDownload Linkmotioncategory_hfilter
Child Hearsay memoThis memo outlines statutes and caselaw involving child hearsay testimony.Word

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adjudication apr practice-resources-for-attorneys termination trial-practice-resourcees
Motion to Introduce Child HearsayThis is a sample motion to introduce child hearsay at a contested hearing.Word

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adjudication apr miscellaneous-motions termination trial-practice-resourcees
Appellate advisement in SpanishThis is a sample appellate advisement in Spanish for Spanish speaking clients.Word

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adjudication appeals termination
Motion for Genetic TestingMotion requesting genetic testing either with paternity presumptions, or a prior adjudication of paternity.Word

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paternity
Motion for Expedited I.C.P.C.Motion requesting expedited ICPC pursuant to Volume 7.Word

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icpc-motions
Tips for appellate advisement after APRThis tipsheet helps trial attorneys make effective advisements after an APR order.Word

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appeals apr practice-resources-for-attorneys
Tips for advising about appealsThis tipsheet provides trial counsel information for effective appellate advisements.Word

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adjudication appeals practice-resources-for-attorneys termination
Motion to Modify Treatment Plan — ADA — MarijuanaThis is a motion to modify a treatment plan to add ADA modificaitons and accommodations, …Word

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ada-accommodations treatment-plan
Case transfer memoThis is a template that can be used when transferring cases to another attorney.Word

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practice-resources-for-attorneys
Treatment Plan ObjectionThis motion objects to treatment plan components requiring parents to attend family team meetings without …Word

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treatment-plan
ICWA Checklist exampleThis example of the ICWA checklist helps attorneys prepare the ICWA section of the opening …PDF

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appeals icwa-motions
ICWA ChecklistThis ICWA checklist helps applellate attorneys prepare ICWA sections of the opening briefWord

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appeals icwa-motions
GAL ConflictMotion addressing conflict with GALWord

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miscellaneous-motions
Motion for finding of no reasonable effortsMotion for finding of no reasonable efforts based on lack of referralsWord

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reasonable-efforts
ICPC caselawThis is a list of ICPC caselaw and resources – last updated 2010PDF

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icpc-motions
Objection to L.A.N.privilege holderThis motion addresses using the privilege to prevent treatment plan complaincePDF

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miscellaneous-motions
Treatment PLan ObjectionObjection to treatment plan components based on 1st amendment, religious freedom.PDF

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treatment-plan
Motion to ContinueMotion to continue termination hearingPDF

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miscellaneous-motions termination
Supplemental AuthoritiesA sample supplemental authorities pleading.PDF

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appeals
Transcript request formThis is the ORPC transcript request form.PDF

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appeals practice-resources-for-attorneys
Notice of Appeal and Designation of RecordThis is the notice of appeal and designation of record form (JDF545) produced by the …PDF

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appeals
Notice of Appeal and Designation of RecordThis is a Microsoft Word template for the Notice of Appeal and Designation of Record.Word

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appeals
Motion for ExtensionThis is a motion for extension of time to file a brief.Word

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appeals
Motion to Supplement and for ExtensionThis is a motion to supplement the record and for an extension of time to …Word

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appeals
Reply Brief TemplateThis is a Microsoft Word template for a reply brief, using headings to automatically create the …Word

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appeals
Opening Brief TemplateThis is a Microsoft Word template for an opening brief, using headings to automatically create …Word

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appeals
Motion for a new trialThis is a C.R.C.P. 60 motion to set aside a default judgmentWord

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adjudication post-trial
Motion for New trialThis is a motion for new trial due to the lack of court appointed counsel …PDF

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post-trial
Motion for New trialThis is a C.R.C.P. 59 and 60 motion for a new trial after a court …Word

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ada-accommodations post-trial
Other Acts EvidenceThis motion in limine moves to exclude evidence of prior bad acts at a termination …PDF

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motion-in-limine
Request for Report WritersThis motion asks the court to order all report writers be present at termination pursuant …Word

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termination
Motion to dismissThis is a motion to dismiss a termination motion pursuant to the UCCJEAWord

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termination
Motion to ContinueThis is a motion to continue an APR hearingPDF

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apr miscellaneous-motions
Response to APR motionThis is a response to a contested motion for allocation of parental responsibilites, and to …PDF

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apr
Motion for APRSample motion for APRPDF

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apr
Motion for APRSample APR motionWord

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apr
limit polygraph useThis is a motion to limit the use of a polygraph in a treatment plan.PDF

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treatment-plan
No approrpriate treatment planThis is a response to a motion for a finding of  no appropriate treatment plan.PDF

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treatment-plan
Waiver of AppealSample wavier of appeal in compliance with CJD 16-02PDF

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adjudication appeals termination treatment-plan
Waiver of appealSample appellate waiver in compliance with CJD 16-02PDF

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adjudication appeals termination treatment-plan
Amend Treatment PlanObjection to amend treatment plan to remove SOMB treatment requirements.Word

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treatment-plan
Rule 60 payment of rentThis motion is for relief from order requiring payment of rent for the other parent.PDF

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post-trial treatment-plan
SOMB treatmentThis is a C.R.C.P. 60 motion for a court to relieve a parent from sex …PDF

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post-trial treatment-plan
Pay rent depositThis is a motion for an order to require the department to pay a rental …Word

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treatment-plan
Pay for DV treatmentThis is a motion for an order requiring the department to pay for domestic violence …PDF

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treatment-plan
Disestablish PaternityMotion to disestablish paternity and request genetic testing when parent was adjudicated paternity in absentia.PDF

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paternity
Petition for Magistrate ReviewPetition for magistrate review of finding of non-paternity and brief in support of petition for …PDF

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magistrate-review paternity
Motion to InterveneMotion for parent not adjudicated legal parent, but who is psychological parent to intervene.Word

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paternity
Police as expertMotion in limine to prevent police officer who responded to child abuse allegations from testifying …Word

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motion-in-limine
Pending ChargesMotion in limine to preclude mention of pending criminal charges.Word

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motion-in-limine
HearsayMotion in limine to preclude admission of documentary and testimonial hearsay.Word

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motion-in-limine
Curtis AdvisementMotion in limine to have Curtis advisement outside the presence of the jury.Word

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motion-in-limine
Credibility OpinionsMotion in limine to preclude witnesses from offering credibility opinions, such as truthfulness, or whether …Word

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motion-in-limine
Exclude administrative findingsMotion in limine to preclude admission of evidence about founded child abuse findings.Word

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motion-in-limine
improper appeals to finder of factMotio in limine to prevent the department and guardian ad litem from appealing to the …Word

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motion-in-limine
Improper appeals to finder of factMotion in limine to prevent the department and guardian ad litem from appealing to the …PDF

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motion-in-limine
Hearsay admissibilityample motion in limine to prevent admission of hearsay.PDF

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motion-in-limine
Exclude Doctor ReportsThis is a motion in limine to exclude hearsay medical reports, including admission of written …PDF

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motion-in-limine
Response to MSJResponse to motion for summary judgmentPDF

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summary-judgment
Response to MSJA sample response to a summary judgmemt motion with an affidavit.PDF

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summary-judgment
Guide for filing Summary JudgmentA guide for RPC filing a summary judgment motion.Word

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summary-judgment
Motion for Summary JudgmentA motion for summary judgment filed by RPCWord

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summary-judgment
Guide to responding to summary judgmentAn RPC guide to respond to a summary judgment motionWord

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summary-judgment
Response to MSJResponse to motion for summary judgment on adjudicationWord

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summary-judgment
Subpoena to Appear or ProduceThis is Judicial’s JDF80 form, the approved and complaint subpoena to appear and or produce. …Word

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discovery
Motion to quash subpoenaMotion to quash subpoena of medical records based on privilegePDF

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discovery
Motion to Exclude drug test resultsMotion to exclude drug testing resultsWord

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schreck-experts
Motion to Strike Discovery requestsMotion to stike discovery requests propounded by the departmentPDF

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discovery
Motion for DepositionThis is a sample motion to request authorization to depose caseworkers.Word

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discovery
Requests for AdmissionThis is a sample pleading of requests for admissions to the department of human services.Word

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discovery
Request for Production of DocumentsThis is a sample pleading of requests for production of documents to the department of …Word

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discovery
Motion for InterrogatoriesThis is a sample interrogatories pleading of interrogatories the department of human services.PDF

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discovery
InterrogatoriesThis is a sample interrogatories pleading of interrogatories to the department of human services.Word

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discovery
Motion for DiscoveryMotion for discoveryprior to terminationPDF

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discovery
Motion for DiscoveryThis is a motion for discovery: interrogatories, requests for production, admissions, depositions, and compliance with …Word

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discovery
Objection to Removal and for Return of ChildObjection to Removal and for Return of ChildWord

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ppp-tch visitation-and-placement
Motion to dismissMotion to Dismiss – Failure to State a ClaimPDF

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adjudication ppp-tch
Motion to DismissMotion to Dismiss petition based on venueWord

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adjudication ppp-tch
Motion for Protective Order § 19-3-207This is a sample motion for a protective order pursuant to 19-3.-207, C.R.S.PDF

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discovery ppp-tch
Entry, Protective Order and DiscoveryThis is a motion that enters an attorney’s appearance, C.R.C.P. 30(b) notice, motion for protective …PDF

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discovery ppp-tch
ADA and Child Welfare Technical AssistanceTechnical assistnace document from US DOJ and HHS guiding complaince with ADA in D&N casesPDF

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ada-accommodations
HB18-1104House Bill 2018-1104 created new statutes and amended several portions of the Children’s Code to …PDF

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ada-accommodations
Disability and HB18-1104 fact sheetFact sheet about HB18-1104, a bill that provides additional protections for parents with disabilities in …PDF

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ada-accommodations practice-resources-for-attorneys
Motion to Amend Treatment planMotion to amend treatment plan to add disability accommodations post HB18-1104.  Accommodations for effective communication.Word

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ada-accommodations treatment-plan
Motion for ADA AccommodationsMotion for ADA Accommodations – Substance Abuse — note not updated with HB 18-1104 statute …Word

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ada-accommodations
Motion for ADA AccommodationsMotion for ADA Accommodations – Intellectual Disability — note not updated with HB 18-1104 statute …Word

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ada-accommodations
Petition for Magistrate ReviewPetition for Magistrate Review ICPC applicationWord

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icpc-motions magistrate-review
Massachusetts ICPC MotionMotion to have ICPC not apply to fit parentPDF

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icpc-motions
Washington DC ICPC MotionMotion to not apply ICPC to fit parentPDF

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icpc-motions
Social Worker Expert AgreementEditable retainer agreement for defense team social workerWord

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practice-resources-for-attorneys social-workers
Motion to Quash Subpoena of defense team social workerMotion to Quash Subpoena of defense team social workerWord

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discovery social-workers
Motion for finding of no reasonable effortsMotion for finding of no reasonable efforts due to failure to follow through on potential …PDF

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reasonable-efforts
Motion for Finding of No Reasonable EffortsMotion for Finding of No Reasonable Efforts for Failure to comply with treatment plan accommodationsWord

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ada-accommodations reasonable-efforts
Motion for finding of no reasonable effortsMotion for Finding of No Reasonable Efforts due to failure to comply with ADAPDF

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ada-accommodations reasonable-efforts
Motion for Finding of No Reasonable EffortsMotion for Finding of No Reasonable Efforts due to failure to work with defense team …Word

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reasonable-efforts social-workers
Motion for Finding of No Reasonable EffortsMotion for Finding of No Reasonable Efforts due to failure to Provide ServicesPDF

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reasonable-efforts
Forthwith Motion for Finding of No Reasonable Efforts and to Establish VisitationMotion for finding of no reasonable efforts and to establish visitation for formerly incarcerated parent.PDF

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reasonable-efforts visitation-and-placement
Motion for Finding of No Reasonable effortseditable stock motion for finding of no reasonable effortsWord

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reasonable-efforts
Motion for Parenting TimeMotion to establish parenting timePDF

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visitation-and-placement
Motion for Finding of No Reasonable Efforts and to Establish Visitation and CommunicationMotion regarding reasonable efforts and establishing vistitationPDF

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reasonable-efforts visitation-and-placement
Motion for ReunifictionA motion for reunificaiton without ICPCPDF

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icpc-motions visitation-and-placement
Motion for Placement with ParentThis is motion for placement of child with a parent.PDF

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visitation-and-placement
Motion to Expand VisitationThis is a sample motion to expand a parent’s visitation in duration, frequency, and for …Word

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visitation-and-placement
Motion for Placement of Child with Family MemberThis is a sample motion to have a child placed with a family member.PDF

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visitation-and-placement
Forthwith Motion to Return Child HomeThis is a sample forthwith motion to have a child returned home because a parent …Word

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visitation-and-placement
ICWA Assessment formJDF 566 ICWA Assessment form for clientsPDF

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icwa-motions
Objection to Change in Visits – ICWAThis motion objects to visit changes in an ICWA case.PDF

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icwa-motions visitation-and-placement
Caseworker expertise voir direThis is a sample voir dire to challenge the expertise of a caseworkerWord

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schreck-experts trial-practice-resourcees
Motion to WithdrawA sample motion to withdraw compling with C.R.C.P. 121 and ORPC Practice standardsWord

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withdrawing
Motion for relief from order regarding 1st Amendment freedomsMotion regaruding right to practice religion of choiceWord

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miscellaneous-motions
Motion for Report Writers Pursuant to C.R.S. § 19-1-107This is a motion asking the court to order all report writers be available to …PDF

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miscellaneous-motions
Motion to Disqualify Judge with affidavitMotion to disqualify judge due to bias. See also affidavit that must accompany motion.PDF

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miscellaneous-motions
Motion to Disqualify CounselMotion to disqualify counsel for intervenor due to conflictPDF

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miscellaneous-motions
Response to CASA ReportThis is a sample response to a court appointed special advocate report, and its recommendations.PDF

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miscellaneous-motions
Response to Motion for L.A.N. OrderResponse to motion for order to designate guardian ad litem as L.A.N. privilege holder.PDF

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miscellaneous-motions
Rise Magazinea free magazine for parents in child welfare cases written by parents who have been …Link

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resorces-for-parents
Parent’s Recommendations for Attorneys in Juvenile CourtRecommendations fromRISE parents for professionals working with parents.PDF

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practice-resources-for-attorneys
Notice of Rights and Remedies for FamiliesColorado form outlineing parents rights and remedeies when a child is placed out of the …PDF

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resorces-for-parents
CJD 16-02Chief justice directive outlining rules for apointments, payments, and practice standards as amended July 2017.PDF

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practice-standards-and-guidelines
ABA Indicators of Success for Parent RepresentationABA study of successful parent representationPDF

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practice-standards-and-guidelines
American Bar Association Standards of Practice for Representing Parents in abuse and Neglect CasesPractice standards from the ABA incorporated into CJD 16-02PDF

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practice-standards-and-guidelines
ORPC Guidelines for Motions to WithdrawORPC detailed practice standard with case citations.PDF

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practice-standards-and-guidelines withdrawing
Using TelelanguageThis information sheet  provides instructions for using telelanguage.Word

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practice-resources-for-attorneys
Volume 7 Rule Manual for Child Welfare ServicesThis links to the most current version of Volume 7.Link

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practice-resources-for-attorneys
Colorado Disability resourcesThis resource guide points attorneys to disability resources, advocacy organizations, and information about governemnt funded …PDF

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ada-accommodations practice-resources-for-attorneys resorces-for-parents
Representation NoticeThis is an editable sample representation notice that can be used when appointed for clients.Word

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practice-resources-for-attorneys
Expert Retainer AgreementThis is an editable sample expert retainer agreementWord

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practice-resources-for-attorneys
Psychological Evaluation Tips for ClientsThis fact-sheet contains tips for clients who are undergoing psychological evaluations, and evaluations with their …Word

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practice-resources-for-attorneys
Practice Tip – Locating Missing ClientsThis fact-sheet gives ideas and resources for locating missing clients, including links to search various …Word

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practice-resources-for-attorneys
Dependency and Neglect Flow ChartThis flowchart shows all the steps in a D&N case, with statutory references.PDF

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practice-resources-for-attorneys

Please email comments to: mgjurekovec@coloradoorpc.org

Revised 8/21/2018