Summary of Annotations Page 40 #1 Highlight Securing Basic Needs, Social Connections, and Appropriate Services • Housing, clothing, food, and transportation are frequently needed and critical to the client being successful in the treatment plan. For example, social workers and parents advocates helping the client access and secure these—from shopping with the client at Goodwill to filling out housing applications to getting on

2 Highlight

Checking in with the client regularly on what is working and what is not, and then advocating for adjustments to the treatment plan. F

3 Highlight

Treating the client as the expert on their own lives and asking them what they need to be successful. #4 Highlight Mitigating structural barriers to treatment engagement Page 41 #1 Highlight Conduct Legal and Social Science Research • Making sure attorneys are working with recent and relevant research when developing strategy (e.g., attachment theory and visitation strategy

2 Highlight

Reviewing Volume 7 and identifying areas applicable to the case #3 Highlight identifying areas of inaccuracy between case proceedings and Volume 7. #4 Highlight Making sure the treatment plan is using evidence-based practices matched to client need (e.g., a mental health service targeted at family functioning versus generic therapy#5 Highlight Reviewing services and strategies to ensure they are accessible (e.g., disability accommodations, language translation), culturally responsive (e.g., honors family customs), and trauma-informed (e.g., in a safe environment) and advocating for adjustments

6 Highlight

Attend family engagement meetings and appearance reviews to support the client, strategize in real time with other actors, and promote communication from other actors to the client in a way the client understands. • Daily communication with other actors that is necessary to move through the D&N process and enact strategy.

7 Highlight

Social workers and parent advocates lead out on promoting a meaningful treatment plan, providing specialized and focused contributions to support client needs, which then make legal advocacy and family strengthening more successful. In

8 Highlight

each member shares in the responsibility of moving the case forward by using available tools with different case actors, with

9 Highlight

attorneys leading this work as “team lead” Page 42

1 Highlight

Median Percentage of Time Contributed by Contractors to Supporting a Client in Addressing their Needs

2 Highlight

Attorneys are keenly aware of critical junctures when a case can stall out, irrevocable decisions are being made, or clients are being set up for failure

3 Highlight

are poised to activate and advance the team in ramping up communication, research, treatment support, and resource connections to disrupt pitfalls at these critical junctures. They are also most adept at navigating legal language and court actors.

4 Highlight

Social Workers have experience with D&N treatment plans and know how to navigate the resources and services named. Th#5 Highlight enables treatment plan advocacy and engagement to be more successful with a variety of child welfare and treatment actor Page 44

1 Highlight

Advocating for the client is the third major activity undertaken by the team—and work

2 Highlight

where high-quality legal representation shines.

3 Highlight

Advocating for the client happens both in and out of court, and this activity is als

4 Highlight

where the team most utilizes experts and investigators

5 Highlight

WHAT Does It Mean to Advocate for the Client

6 Highlight

Hold State Actors Accountable:

7 Highlight

accountable to their burden, responsibilities, and obligations by leveraging available mechanisms

8 Highlight

Ensure Appropriate Fact Finding:

9 Highlight

Ensuring due process by

10 Highlight

identifying and obtaining experts,

11 Highlight

investigators, or witnesse#12 Highlight obtaining and reviewing records, plans, reports, or other pertinent documents; observing visitations, related cases, or other meetings to obtain information

13 Highlight

to inform strategy development

14 Highlight

Preparing for litigated hearings, including preparing the client themselves, and representing the client in court.

15 Highlight

Hearing representation and fact finding are largely led by the attorney, in collaboration with experts and investigators.

16 Highlight

Social workers and parent advocates provide vital support to attorneys in accomplishing these tasks, as

17 Highlight

It is holding the Department accountable outside of a court issue [e.g., service referral

18 Highlight

and it is also holding the court accountable to keeping the Department honest and doing their reasonable efforts a

19 Highlight

making sure that they are actually connecting parents with the services that are needed

20 Highlight

You are the gatekeepers Page 45

1 Highlight

HOW Does the Team Accomplish This in Practice? HOLD STATE ACTORS ACCOUNTABLE

2 Highlight

following up with the Division of Child Welfare to ensure timely delivery of services an#3 Highlight Ensuring the treatment plan is done i

4 Highlight

collaboration with the parent

5 Highlight

tailored to need

6 Highlight

dynamics of the child-parent relationship (e.g., age, bonding issues

7 Highlight

Calling in when court reports are biased towards the negative and not elevating what the parenting is doing well (i.

8 Highlight

advocating for k

9 Highlight

placements

10 Highlight

Confronting systemic racism through simply being present

11 Highlight

elevating concerns to the team for strategy development

12 Highlight

“I find myself fighting that [visitation] fight a lot fo Page 46

1 Highlight

HOW Does the Team Accomplish This in Practice? ENSURE APPROPRIATE FACT FINDING

2 Highlight

Investigators, Experts#3 Highlight To secure evaluations, assessments, and diagnoses that can be used in strategy

4 Highlight

testify to appropriate services and supports for redressing allegations

5 Highlight

ensure a full, multi-angle account of client allegations and needs.

6 Highlight

Attending/observing family engagement meetings, visitations, and related cases to bear witness to what actually happens

7 Highlight

and be a source of information to the team and

8 Highlight

the courts.

9 Highlight

Checking in with the client regularly and knowing what is happening in their lives as a form of “working intelligence” for attorneys.

10 Highlight

Reviewing extensive medical records

11 Highlight

legal reports

12 Highlight

documents that inform root causes of systems involvement and identifying strategies positioned to help redress.

13 Highlight

Obtaining and reviewing discovery

14 Highlight

Trails records, investigation reports#15 Highlight Family Safety and Risk Assessme

16 Highlight

hold “same-page” information as the Department

17 Highlight

Attorney drafting of discovery requests

18 Highlight

motions.

19 Highlight

Preparing the Client for Court

20 Highlight

ensuring they know strategy for

21 Highlight

this court session

22 Highlight

what is appropriate for this hearing versus another space) Page 47

1 Highlight

calling in when court reports are biased and not uplifting client strengths they observed

2 Highlight

Fact finding is led by the attorney, with the support of social workers who commonly take on documentation review and provide working intelligence to the team.

3 Highlight

Reminder Holding state actors accountable was a prime theme in qualitative narratives Page 48#1 Highlight How Frequently Does the Team Use Experts and Investigators? Importantly, use of experts and investigators is a strategy under ensuring appropriate fact finding,

2 Highlight

Parent Advocates

3 Highlight

find out what is really going on—

4 Highlight

barriers

5 Highlight

strengths—and

6 Highlight

knowledge and time necessary to review documentation

7 Highlight

accompany the client to meetings, creating deep sources of information for accountability, hearing preparation, and fact finding. Page 49

1 Highlight

I’ve had things like intellectual disability come to light and then I work with the attorney to adopt new things in the treatment plan and advocate for that i

2 Highlight

Just making sure we’re not missing something that is impeding our client’s ability.” Page 50

1 Highlight

comprehensively understand a client’s needs,

2 Highlight

to inform case strategy and amplify client voice.#3 Highlight Advocacy Support: Calling in systemic bias of the courts and of child welfare and

4 Highlight

advance

5 Highlight

socially responsive strategies

6 Highlight

ORPC model of interdisciplinary representation is

7 Highlight

model for systems change of child welfare proceedings. Page 56

1 Highlight

Office of the Respondent Parents’ Counsel (ORPC): Interdiscplinary Teams for Successful Client-Centered Representation Page 58

1 Highlight

complex case needs

2 Highlight

histories can require additional advocacy

3 Highlight

specialized support to

4 Highlight

trau

5 Highlight

case higher risk for family separation a Page 59#1 Highlight have disabilities, and/or who face extensive resourcing challenges related to housing, food, and economic security. In addition, social workers bring experience in navigating the child welfare system and intimate knowledge of Volume 7 that supports attorneys

2 Highlight

Department obligations

3 Highlight

options for tailored client support.

4 Highlight

Mental Health

5 Highlight

Disability:

6 Highlight

Trauma,

7 Highlight

Clients facing housing, food, and economic insecurity need additional support and resource connections to break cycles of systems involvement and poverty.

8 Highlight

Volume 7 Accountability:

9 Highlight

Cases where the Department is not fulfilling obligations

10 Highlight

require extensive monitoring

11 Highlight

diligence;

12 Highlight

especially true when inexperienced caseworkers are assigned#13 Highlight show what is possible in #14 Highlight build client confidence #15 Highlight ensuring that family voice leads in every step of the case. #16 Highlight Social and Structural Inequities: Page 60 #1 Highlight team model is best suited for complex cases #2 Highlight where social and structural inequities are rampant, #3 Highlight model can act as a “leveling up” factor #4 Highlight outcomes are more equitably achieved

"from what I've heard" HALEY. FUCKING HALEY.

FUCKING FCS AND STATE ATTORNEY.

JUDGE - SERIOUS ISSUE

McLean - âre you saying "child doesn't want to talk to Dad" is GROUNDS?? Is that your argument?

Oh do you wish to claim something else as grounds? Homeless? Abuse? Ok, what's your evidence and what's respondents response?

Just like the omissions by FCS. No doubt in the GRID, the very first act of every case and every new Respondent attorney would be an immediate client interview and motion updating the facts of the petition

The ORPC calls this pdf the "ORPC-Handbook.pdf"

ALL OF THESE ANNOTATIONS....HUGE REASONABLE EFFORTS ISSUES

you were deprived of this; you also knew I had huge medical concerns from the qrtp hearing and knew the independent assessment had not been carried out and huge red flags existed

Fuck you haley...gonna have your fucking license

"Upon filing of a demand by any party wherein a trial by jury is provided by statute, all issues of fact shall be tried by a jury"

AND THIS STATEMENT FROM THE COLORADO JUDICIAL BRANCH (And mag. McLean heard from my mouth I wanted a trial): What is the court process in dependency and neglect cases? A dependency and neglect case begins with the filing of a petition by the county attorney or, in Denver, the city attorney. Parents who are listed in the D&N petition are referred to as “respondents.” You are required to appear in court and at that time, you may deny the allegations against you and demand that the case then be heard at trial by a jury of six people, by a judge, or by a juvenile magistrate. https://www.courts.state.co.us/userfiles/File/Media/Brochures/d&nweb.pdf

See: https://hyp.is/go?url=https%3A%2F%2Fcasetext.com%2Fstatute%2Fcolorado-revised-statutes%2Ftitle-19-childrens-code%2Farticle-3-dependency-and-neglect%2Fpart-2-general-provisions%2Fsection-19-3-202-effective-until-112024-right-to-counsel-and-jury-trial&group=world

Section 27-65-102 - Definitions (22) "Mental health disorder" includes one or more substantial disorders of the cognitive, volitional, or emotional processes that grossly impairs judgment or capacity to recognize reality or to control behavior. An intellectual or developmental disability is insufficient to either justify or exclude a finding of a mental health disorder pursuant to the provisions of this article 65.

Section 19-3-506 - [Effective Until 7/1/2024] Child with a mental health disorder or an intellectual and developmental disability - procedure√

(b) If it appears from the evidence presented at an adjudicatory hearing or otherwise that a child may have a mental health disorder, as defined in section 27-65-102,

the court shall order a prescreening to determine whether the child requires further evaluation. The prescreening must be conducted as expeditiously as possible, and a prescreening report must be provided to the court within twenty-four hours

c) If the mental health professional finds, based upon a prescreening done pursuant to this section or section 19-3-403 (4), that the child may have a mental health disorder, as defined in section 27-65-102, the court shall review the prescreening report within twenty-four hours, excluding Saturdays, Sundays, and legal holidays, and order the child placed for an evaluation at a facility designated by the commissioner of the behavioral health administration

(d) An evaluation conducted pursuant to this subsection (1) must be completed within seventy-two hours, excluding Saturdays, Sundays, and legal holidays. A county jail or a detention facility, as described in article 2.5 of this title 19, is not considered a suitable facility for evaluation,

My statement in court to McLean I wanted a trial was a clear motion

ABA: Motion for Summary Judgment (sometimes called motion for summary disposition). This motion asks the court for a judgment on the merits of the case before the trial. It is properly made where there is no dispute about the facts and only a question of law needs to be decided.

The was A HUGE DISPUTE of the facts. Not only the facts presented, but also the omission, AND ALSO THAT I NEVER HAD 1 CHANCE TO SPEAK AND STATE ANNNY FACTS! And, as federal civil procedure rules state, summary judgement can only occur after the close of Discovery...we NEVER HAD DISCOVERY

The motion was filed 45 days prior to trial. ...I mean, beyond Haley being criminally fucking useless, when does the judge become accountable for not letting illegal shit happen in her case???? Regardless of what the attorneys do; isn't she the "trier of law" and "trier of facts"? I mean, what the fuck??

Method for defense, hold accountable, stop unlawful abuse? - sue for damages for loss and harm - writ of mandamus (oblivious to Haley) - when does not following law that results in withholding of a child go from civil damages to criminal kidnapping or custodial interference (and other offenses). Kate, FPS, and court was heedless' of lawfulness, enticed', with intent to conceal', and did not have reasonable' belief or attempt reasonable efforts' as expected of a reasonable peer to aquire reasonable belief' she was in harm. Clarity: the child's own instigation' was result of enticement' CRS TITLE 18 https://victimtohero.com/interfering-with-custody-is-not-just-a-civil-matter-it-is-a-crime/

TRIAL BY JURY MANDATED....HALEY....YOU FUCKING SHAMEFUL INEXCUSABLE IMPOSTER OF AN ATTORNEY. Shaun, do you know about this? Does an appeal attorney for ORPC know the D&N law of which he'll be making appeals?

See: https://hyp.is/go?url=https%3A%2F%2Fcasetext.com%2Frule%2Fcolorado-court-rules%2Fcolorado-rules-of-civil-procedure%2Fchapter-5-trials%2Frule-38-right-to-trial-by-jury&group=world

I don't remember her doing this. She sure as fuck didn't execute it.

Haylie is not providing any information to the judge, e.g.: - harboring not addressed - intake lied - intake failed to meet promise - intake actually DROVE removal, as in "negative reasonable efforts" - intake did not provide allegations at first contact or ever; and also therefore, 2., did not collect response, and necessary danger data and necessary services/needs data - intake did not provide, therefore, a credible report informing court of true nature - intake offered no FFPSA designated services nor Core Services Program services - intake provided no list of services offered/provided, no list of identified needs, no explanation of how it succeeded or failed - magistrate did not examine, inquire, or document specifically and detailed the reasonable efforts in "The Prevention Plan"...I've seen no Prevention Plan and certainly not filed with the court - Visitation scheduler: 1) not competently trained in youth or resist and refuse; only 1.5 years licensed (probably no clinical practice) and self identified adult addiction, 2)provided no scientific backing for recommendations, omitted context to misrepresent truth, did not identify needs, provided no plan to resolve/address those needs especially science-backed (and found to be an intern), 3)was 3+ weeks late for 1wk due date - caseworker was assigned over a month later and is mandated to be immediate at time of 1st hearing - CASA was not assigned until 4 months later and i've still never heard from them - caseworker was told must provide allegations report and still did not and would not - family needs assessment was never done, certainly not in my presence, nor with my collaboration and agreement, if in the background there is one it is a lie or of completely insufficient quality and was not reported to me when asked for. It was not done even close to 60 day (therefore also does not meet mandate of "timely") deadline (and if it's dated as such it is a complete BS non-assessment only for the purposes of making it show up on a log as done). It does not identify needs/problems (most importantly resist/refuse) that brought forth D&N, it does not identify services that address the particular needs (most importantly a resist/refuse doctor; also actively blocked FUP) (and therefore nothing is science based "trauma informed" as mandated), it does not mandate what must be changed/achieved and the marker for that achievement; I still was not given Service Plan when I pried and pried for clear list of items that brought forth D&N-what was needed to change/achieved to end State's involvement-what services were/could/wanted to be done - DHS has failed to investigate it's actions of abuse to confirm/deny; which in the case that abuse did not happen 2. has failed to meet "timely" mandate of services to medically assess and treat resist/refuse and 3. failed "reasonable efforts to reunify" mandate - DHS has not only 1. failed mandate to offer/make available/refer & monitor and ensure execution of services/ (e.g. Core, FFPSA, "unique to family needs", "public or private/community bases", "evidenced based", "trauma informed...further defined in CCR as "complete situation assessment/treatment, whole family") they 2. made ME responsible for REFERRING THEM and with an expectation it likely WOULD NOT BE PURSUED, 3. was essentially told Core Services wasn't real (was ignored and then simply would not answer when i asked directly in-person about "Core Services" and changed the subject) when I specifically asked, 4. mocked when I gave science backed warning of imminent and severe risk and necessary doctor services needed - court did not set adjudication until 2+ months past federally mandated 90 day MAXIMUM (and is written as "should be much sooner and ASAP", and 2. almost 4 months after 20th District's filed D&N management commitment plan - Independent Assessment: did not meet many many mandates (see email to Haylie on objection to recommendation) - QI did not include family, claims 6 attempts to call but did not as mandated provide evidence of attempts, State did not meet mandate to make sure family was included in the process and ACTIVELY KEPT MOM & DAD & ATTORNEYS as mandated of the mandated Family and Permancy Team Meeting; did not complete in 10/14 day CDHS mandate nor did complete in 30 day federal requirement (which is also contractually owed by ASO); never held a 2nd Team meeting as requested (which resulted in a ruling based on false argument that would have been quashed in the meeting and also the QI realizing and changing her recommendations with the knowledge that the false claim was not only indeed false but that the credibility of information provided by state & CYF was now in question; and ultimately a result of a QI would have full & true understanding of medical need and severity and harm befalling child and family and would have urgently recommended necessary interventions which had so long been failed to be recognized/provided by State) - Court nor State was informed of fundamental FFPSA law as is absolutely expected to be known by a Child Welfare Judge and Child Welfare Attorney and Child Welfare Agency, at QRTP Assessment Review Hearing and made ruling on completely false law justification that child is not legally allowed to remain at the QRTP [b/c of course she is, which is the whole point of the hearing, b/c it's up to judge to determine if she should stay or not regardless of IA summary report recommendations

Really Haley?? You could not argue that,

1) there was no genuine dispute over the material facts....over "what happened, AND what realities/possibilities/options/resources/outcomes exist" ????

2) that I was not entitled to "judgment" regardless of "material facts being in dispute" OR NOT "in dispute". For starters, a for a trial review of the facts regarding the determination of grounds that have been brought forth, not brought forth, and mis-presented, and additional are due and necessitate the compelling process of discovery in order to assure provision of, and of which a collection is already known by respondent and counsel to exist which the court has not been made of and who's determined clarity resulting from the analytical vetting the trial will provide holds the potential power to not just determine whether the state had grounds, but regardless of that outcome, to help all parties determine collaboratively and aided by the authoritative might of the court how the state can best provide help and services going forward, including if appropriate removing themselves from intruding a moment further in this family's lives and liberties. .... FACTS I'VE BEEN SHOUTING AT YOU FROM DAY ONE AND IN A MILLION EMAILS TO YOU OR BEEN CCED. YOU'RE A FUCKING MORON, BY WAY OF UNLAWFUL COMPETENCY OR NEGLECT TO YOUR CASE, YOUR DUTY TO SELF INFORM, AN ENTRUSTED BY AND SWORN TO THE PEOPLE OATH, AND YOUR KNOWN DUTY TO THE DEADLY VALUE, PURPOSE, AND CONSEQUENCE OF YOUR POST, a post for which you are additionally compelled to perform by, albeit less importantly, a meaningful wage.

Reasonable Efforts - not so much RE as it's criminal malpractice. Jackie released confidential case information, purposefully AND misrepresented it. Also CCR 7.601 protect confidentiality. 12 CCR 2509-7 https://hyp.is/UaaebvvTEe2eeDeCZWyDVw/docdrop.org/download_annotation_doc/12-CCR-2509-7-43cgo.pdf

You don't do you? ....but reunification "is the goal" right Jackie?

Jackie (FCS) is prohibited from sharing any information about the case

Reasonable Efforts - not so much RE as it's criminal malpractice. Jackie released confidential case information, purposefully AND misrepresented it. Also CCR 7.601 protect confidentiality. 12 CCR 2509-7 https://hyp.is/UaaebvvTEe2eeDeCZWyDVw/docdrop.org/download_annotation_doc/12-CCR-2509-7-43cgo.pdf

Reasonable Efforts - not so much RE as it's criminal malpractice. Jackie released confidential case information, purposefully AND misrepresented it. Also CCR 7.601 protect confidentiality. 12 CCR 2509-7 https://hyp.is/UaaebvvTEe2eeDeCZWyDVw/docdrop.org/download_annotation_doc/12-CCR-2509-7-43cgo.pdf

As previously described, Colorado has a strong foundation and history of providing prevention and early intervention services through the use of Core Services, IV-E Waiver interventions, CMPs and integrated human services delivery. In addition,

75.4 PARENTAL ALIENATION: A SPECIFIC EXAMPLE OF CHILD PSYCHOLOGICAL ABUSE William Bernet, MD, Vanderbilt University Medical Center, william.bernet@vanderbilt.edu

Conclusions: Indoctrinating a child to hate or fear a parent without a good reason is a form of child psychological abuse. Clinicians should use the DSM-5 diagnosis of child psychological abuse when an alienating parent is deter- mined to cause parental alienation in his or her children. Child protection personnel should investigate cases of parental alienation as instances of child psychological abuse. CAN, FAM, FCP http://dx.doi.org/l O. 1016/j.jaac.2017.07.439

What she could have received if she stayed at the QRTP (if Haylie knew the law; if DHS, Ramirez, Beato, McLean also knew and performed their job core competencies)

Nikki Getz was the "qualified" brainchild to recommend depriving her of all this. I even have her recorded saying it is a serious issue that she has continued adamant contact refusal

Would have addressed the 1) family dysfunction need that brought DHS to be involved, 2) reasonable efforts for reunification 3)ffpsa mandate for family preservation, involvment, trauma-informed, 4) identified needs/wishes of family

Could of had a Child & Adolescent Psychiatrist coordinating care, instead of a dipshit LCSW intern. And contribute to FFPSA mandate for trauma-informed, highest available science, evidence based

Could have finally had a treatment plan

The umm "plan" from Allison and Kim was Rhyanna see her therapist until she spontaneously decided to re-engage. Did the outpatient solution work? No. Did it get worse? Yes. She was put on an M1 hold. She is in QRTP for over a month and the argument was "she's doing so well [other than the enormous symptom of contact-refusal] has not improved at all] so, what your saying, should be taken out of the treatment that has shown improvement [i.e. QRTP], and take her out before the largest issue has been solved and put her into a "no treatment" facility? SERIOUSLY??

PROGRAM AREAS, CASE CONTACTS, AND ONGOING CASE REQUIREMENTS 12 CCR 2509-3

7.200 PROGRAM AREAS, CASE CONTACTS, AND ONGOING CASE REQUIREMENTS

not providing me the allegations and getting a response violates reasonable efforts

Judge Edwards is a retired judge now working as a consultant to juvenile courts in California and other states. The author can be contacted by email: judgeleonardedwards@gmail.com or by visiting his webpage: judgeleonardedwards.com.

- The author is indebted to many people for the research and information contained in this book. In particular, I thank Sidney Hollar, Esq. for her assistance with the text, Christopher Wu, Marymichael Miatovich, and Judge Arnold Rosenfield (ret.) for their suggestions regarding the text, Jackie Ruffin for her work on the footnotes, Dave Bressler for his technical assistance, and Anna Bokides for her assistance with research. Additionally, I thank all of the judges, attorneys, and CIP directors who commented on how the reasonable efforts issue is tried in their jurisdictions. Finally, I thank Casey Family Programs for their generous support in making the publication of this book possible. Judge Leonard Edwards (ret.)

Cannot retroactively add to the orders or documentation to bolster the (false) fact that court diligently examined and found specific findings of reasonable efforts

I have seen no mention of "core services", "ffpsa", or any services afforded under them from Boulder County or on their website. Nor did Allison acknowledge them.

Thoughts: So far it appears there is no law about who can diagnose. What there is is: - description of a rubric to grade a expert witness - general description that states cannot operate outside area if training and competence (but how to define that area is absent) - core services / FFPSA law mandating evidence based, trauma Informed, Clearinghouse designated, best available science, meet particular needs of family - law (or in draft) defining trauma Informed - licensing and professional associations standards and code of ethics regarding non black and white values and efforts mandates - there are laws that say if you can call yourself a doctor, therapist, etc, but non if them limit what they can or cannot do - therefore, legally, anyone can diagnose anyone with anything, including DSM codes, and you can take money for it...you just can't call yourself any of the protected titles

So, when it comes to who is "legally qualified" or a "legally allowed expert", (which is just the expert, and not ultimately the credibility of the "evaluation/recommendation" it comes down to just who can provide a stronger argument that the expert in question is "more expert" than the other "expert". It's the exact same concept as scientific theory. You can't "prove" a scientific theory. You can only provide increasingly stronger (ultimately just means, whether for good reasons or bad, the emotion that something feels stronger or better) arguments that it is true. As in you can't prove "expertise" or that an eval is correct. However, you can "disprove" expertise or scientific theory.

In psychotherapy there is an enormous gap of a system that gives a credible prediction of what a "provider" is likely to soundly be able to evaluate (and further a system for them to soundly know when and how to refer out). Perhaps some kind of "certifications needed" section for each DSM code.

So what you can do is: - used the defined law and prof orgs law and ethics as rubrics (like a grading table), the table in this paper is a good one to incorporate, to make an argument of strongest expert. - you can also get more than one expert or experts from different areas which have all of them agreeing - strategy: also send evaluation off to credible authority to get their endorsement - strategy: do that memorandum thing (ABA guide how to influence judges) to advance submit law and argument to judge - all of this is the exact same issue, concept, and strategy to battle "reasonable efforts"

This doc is cited in ABA FFPSA legal guide, research to site to overcome reasonable efforts to reunify https://hyp.is/p-iA6tdvEe2Nz5fQQrBXwg/docdrop.org/download_annotation_doc/family-first-legal-guide-a8rhd.pdf

ABA list of resources to cite to overcome lack of reunification

Families should be provided all needed assistance to ensure the safe reunification of the child

No documentation of specific prevention measures of reasonable efforts was done

"request "no reasonable efforts" finding and order returning the child to family with appropriate services"

Referenced from 19-3-100.5 Legislative declarations - reasonable efforts

the general assembly provides that “reasonable efforts” are deemed to be met when a county or city and county provides services in accordance with section 19-3-208

https://hyp.is/go?url=https%3A%2F%2Fadvance.lexis.com%2Fdocumentpage%2F%3Fpdmfid%3D1000516%26crid%3D9d70f7cb-1878-426e-ad25-f4c8dd3dabea%26nodeid%3DAATAAGAACAAB%26nodepath%3D%2FROOT%2FAAT%2FAATAAG%2FAATAAGAAC%2FAATAAGAACAAB%26level%3D4%26haschildren%3D%26populated%3Dfalse%26title%3D19-3-100.5.%2BLegislative%2Bdeclarations%2B-%2Breasonable%2Befforts%2B-%2Bmovement%2Bof%2Bchildren%2Band%2Bsibling%2Bgroups.%26config%3D014FJAAyNGJkY2Y4Zi1mNjgyLTRkN2YtYmE4OS03NTYzNzYzOTg0OGEKAFBvZENhdGFsb2d592qv2Kywlf8caKqYROP5%26pddocfullpath%3D%2Fshared%2Fdocument%2Fstatutes-legislation%2Furn%3AcontentItem%3A61P5-WT61-DYDC-J3FS-00008-00%26ecomp%3D8gf59kk%26prid%3Dbc310e45-27f6-4bc6-b939-0b56a2f4fa4e&group=world

C.R.S. 19-3-100.5