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Taylor McLaren
Respondent pro se
78 South Main Street
Hyde Park, Utah 84318
In The Matter Of,
NICHOLAS MCLAREN
RILEY MCLAREN
MICHAEL MCLAREN,
Children
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) INTERROGATORIES AND REQUEST
FOR PRODUCTION OF
DOCUMENTS
Case No. 02J4897
Case No. 02J4898
Case No. 02J4899
Please respond to the following Interrogatories and Request for Production of Documents, in accordance with the Oregon Rules of Civil and of Juvenile Procedure:
INTERROGATORIES
1. Please describe in detail the significant emotional issues referred to in Paragraph 2(1) of the Petition. For each such issue, please describe:
a. The date and place of each incident relied upon in determining each such significant emotional issue.
b. Any other facts relied upon in determining the existence of each such significant emotional issue.
c. Those sections of the DSM IV relied upon in determining the existence of each such significant emotional issue.
d. The name, address, and telephone number of each person who made the determination of each such significant emotional issue.
e. The qualifications of each such person to make a determination of each such significant emotional issue.
2. Please describe in detail the significant mental issues referred to in Paragraph 2(1) of the Petition. For each such issue, please describe:
a. The date and place of each incident relied upon in determining each such significant mental issue.
b. Any other facts relied upon in determining the existence of each such significant mental issue.
c. Those sections of the DSM IV relied upon in determining the existence of each such significant mental issue.
d. The name, address, and telephone number of each person who made the determination of each such significant mental issue.
e. The qualifications of each such person to make a determination of each such significant mental issue.
3. Please describe in detail each incident referred to in Paragraph 2(3) of the Petition in which the Respondent has engaged in suicidal gestures and/or attempts and has made previous threats to harm herself and the children. For each such incident, please describe:
a. The date, time, and location of each such incident.
b. The conduct and statements constituting each such incident.
c. The name, address, and telephone number of each person who witnessed each such incident.
d. The name, address, and telephone number of each person who made a determination that such incident constituted a suicidal gesture, a suicidal attempt, a threat to harm herself, or a threat to harm the children.
e. The qualifications of each such person to make such a determination.
4. Please describe in detail each incident referred in which DHS attempted to engage the Respondent in services, as referred to in paragraph 2(4) of the Petition. For each such incident, please describe:
a. The date, time, and location at which each such service was offered.
b. The specific service that was offered.
c. The name, address, and telephone number of each person who offered each such service.
5. Please describe in detail each incident referred in which law enforcement attempted to engage the Respondent in services, as referred to in paragraph 2(4) of the Petition. For each such incident, please describe:
a. The date, time, and location at which each such service was offered.
b. The specific service that was offered.
c. The name, address, and telephone number of each person who offered each such service.
6. Please set forth any sections of the Oregon statutes, any federal statues, any Oregon case precedents, or any federal case precedents that require a party to accept services offered by DHS or law enforcement.
7. Please set forth any sections of the Oregon statutes, any federal statues, any Oregon case precedents, or any federal case precedents that require the Court to assume jurisdiction and/or make a finding of abuse, neglect, or child endangerment upon finding that a party has declined to accept services offered by DHS or law enforcement.
8. Please provide the name, address, and telephone number of each person whom the Petitioner intends to call as a witness at adjudication of the above-entitled matter.
9. Please provide the name, address, and telephone number of each person whom the Petitioner relied upon in formulating the allegations in the Petition.
10. Please provide the name, address, and telephone number of each person whom any Attorney for the children intends to call as a witness at adjudication of the above-entitled matter.
11. Please provide the professional qualifications, employment history, and criminal history of each person named in response to Interrogatories 8, 9, and 10.
REQUEST FOR PRODUCTION OF DOCUMENTS
12. Please provide copies of all documents which the Petitioner intends to introduce in support of the allegations contained in the Petition.
13. Please provide copies of all other documents which the Petitioner intends to introduce at Adjudication of the above-entitled matter.
14. Please provide copies of all documents which any Attorney for the children intends to introduce in support of the allegations contained in the Petition.
15. Please provide copies of all other documents which any Attorney for the children intends to introduce at Adjudication of the above-entitled matter.
16. Please provide copies of all documents relied upon by the Petitioner in formulating the allegations contained in the Petition.
DATED this 16th day of November, 2002.
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Taylor McLaren
Certificate of Service
I hereby certify that I mailed a copy of the foregoing to the following this 18th day of November, 2002:
Dawn McIntosh
Assistant District Attorney
Clatsop County Courthouse
P.O. Box 835
Astoria, OR 97103 Mary Ann Murk
c/o Circuit Court
Clatsop County Courthouse
P.O. Box 835
Astoria, OR 97103 Paul Flannery
3918 Northeast 35th Circle
Vancouver, WA 98661