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Click to go the Brief
Sample Guardian ad Litem
Brief 01
Word Document Format
I.
There was no less drastic alternative.
Sample Guardian ad Litem
Brief 02
Word Document Format
II.
Mother's right to counsel.
Sample Brief 12
Delinquency Review
Word Document Format
I.
The trial court erred in making its Curtis advisement.
II.
The trial court erred in admitting CRE 404 evidence.
I.
The department of
social services’ failure to provide subpoena copies to father j.r.g.
Violated due process.
II.
The department of
social services’ failure to sufficiently summarize the testimony of its
witnesses prior to trial violated due process.
III.
The insufficiency of
the department of social services’ termination motion violated due
process.
IV.
The cumulative effect
of these errors, and the trial court’s failure to grant a motion for
continuance, violated due process.
I. The
conclusions of certain experts must be disregarded because they were
based on hearsay evidence not otherwise introduced at trial.
Ii. The juvenile court improperly admitted certain evidence.
Iii. There was not sufficient competent evidence for the court to
sustain its findings by clear and convincing evidence.
I.
The trial court’s due process errors aversely affected the
outcome of the case.
II.
There was insufficient evidence to prove clearly and convincingly
that there was no less-drastic alternative
I.
The
trial court’s findings about less-drastic alternatives to termination
were insufficient.
II.
The facts elicited by the denver department of social services at
the termination hearing were so summary as to not meet the statutory
burden of clear and convincing evidence.
I.
The guardian ad litem’s failure to attend all of the termination
hearing is plain error and requires a new hearing.
Ii. There
were reasonable alternatives to termination
I.
The trial court improperly disallowed relevant evidence of
respondent mother’s past after objection.
II.
The effective duration of respondent mother’s treatment plan was
too short as a matter of law.
I.
The trial court’s refusal to provide sequestration sanctions
prejudiced respondent mother.
II.
The guardian ad litem’s failure to attend all of the termination
hearing is plain error and requires a new hearing.
III.
There was insufficient evidence to prove clearly and convincingly
that there was no less-drastic alternative.
I.
Termination of parental rights and adoption by paternal
grandfather is not, in this case, logically different from permanent
custody, guardianship, or long-term foster care
II.
In this unusual case father J.A.B. joins in the objections and
arguments of respondent mother for purposes of this appeal.
I.
The petitioner violated the law requiring reasonable efforts.
II.
The trial court erred in finding that there were no less- drastic
alternatives.
III.
The evidence did not address the adoptability of one of the
children.
I.
The trial court allowed improper lay testimony of witness
Thompson after objection.
III.
The trial court abused its discretion in not striking the motion
for telephone testimony by witness Thompson.
IV.
The trial court abused its discretion in allowing telephone
testimony by witness Thompson.
V.
The evidence concerning termination and the children was not
clear and convincing.
I.
The trial court erred in admitting father’s department of
corrections record.
II.
The trial court erred in finding that there were no
less-restrictive alternatives.
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