ATTORNEY #12345

Utah County Public Defender’s Association

180 North University Ave., Suite 180

Provo, Utah 84601

Telephone: (801) 852-1070

e-mail address: Attorney@utcpd.com

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IN THE FOURTH DISTRICT JUVENILE COURT

UTAH COUNTY, STATE OF UTAH

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STATE OF UTAH In the Interest Of: DOE, JONNY 12-31-1999 Person under eighteen (18) years of age	REQUEST FOR DISCOVERY, PRODUCTION OF DOCUMENTS AND REQUEST FOR WITNESS AND EXHIBIT LISTS Case No. ******* Judge Iron Man

COMES NOW, the Mother/Father, Jane/John Doe, by and through counsel, Attorney, and hereby submits the following Request for Production of Documents to the Attorney General and the Utah Division of Child and Family Services.

REQUEST FOR PRODUCTION OF DOCUMENTS

Pursuant to Utah Rule of Civil Procedure 34, Mother/Father hereby submits the following Request for Production of Documents upon the Utah Division of Family Services. In answering this Request, the law requires that the answering party utilize all information that is available to the answering party, including information in the possession of the answering party, its agents or attorneys, as well as any information over which the answering party, its agents or attorneys exercise control.

Note also that this Request is deemed continuous and shall require supplemental answers

pursuant to Rule 26 of the Utah Rules of Civil Procedure. In the event that further responsive documents come into the possession, custody or control of an answering party after this Request has been answered, the answering party is required to supplement its response within a reasonable period of time after receiving such documents.

Mother/Father hereby requests the following documents from the answering parties:

Any documents that summarize, record or reference statements made by

the above-named r child(ren) concerning the allegations of the Verified Petition, or any other substantive pleading filed in this matter.

Any documents that summarize, record or reference statements made by

Mother/Father concerning the allegations of the Verified Petition, or any other substantive pleading filed in this matter.

Any documents that summarize, record, or reference any information you

relied upon in formulating the allegations of the Verified Petition or any other substantive pleading filed in this matter.

Any documents that summarize, record, or reference any information upon

which you plan to rely on to establish the truth of the allegations of the Verified Petition or any other substantive pleading filed in this matter.

Any documents that summarize, record, or reference any information that

does not support the allegations of the Verified Petition or any other substantive pleading filed in this matter, including any and all information that tends to refute the truth of the allegations of the Verified Petition or pleading.

Any CPS or DFS activity logs, transportation logs, referral forms, risk

assessment forms, or other documents pertaining to this matter.

Any medical or psychological evaluations pertaining to this matter.

Any police reports pertaining to this matter.

Any documents derived from any foster parent, shelter parent, or kinship

placement pertaining to this matter.

Any other letters, reports, or summaries, generated from any source,

pertaining to this matter.

Any photographs that summarize, record, or reference any information

that does or does not support the allegations of the Verified Petition, or any other substantive pleading filed in this matter.

REQUEST FOR WITNESS AND EXHIBIT LISTS

The Mother/Father, by and through counsel, Attorney of the Utah County Public Defenders Association, hereby requests the State of Utah provide a list of the individuals who they intend to call as witnesses to testify at the trial in the above-entitled matter, and a brief summary as to what each individual will testify, and a list of all Exhibits planned to be introduced.

DATED this 31st day of December 1999.

___/s/ Attorney____________

ATTORNEY NAME

Utah County Public Defender Association

CERTIFICATE OF SERVICE

The undersigned hereby certifies that on [] day of Month 1999, I caused a true and correct copy of the foregoing to be delivered to the following:

Ironman DCFS tstark@utah.gov	Sent via: _____ Hand delivery at court _____ Email
Captain America Guardian ad Litem	Sent via: _____ Hand delivery at court _____ Email
Loki Assistant Attorney General	Sent via: _____ Hand delivery at court _____ Email
Ultron Counsel for Mother/Father	Sent via: _____ Hand delivery at court _____ Email

___/s/ Attorney____________

ATTORNEY NAME

Utah County Public Defender Association