#4, Drano Series
| In Harm's
Way*
*Petition for Interlocutory Relief, Supporting Memorandum of Law, and Motion for Stay of Order of Probate & Family Court Pending Appeal |
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APPEALS COURT ESSEX, SS. C.A. NO. ________ ---------------------------------
v. Susan Pane
MOTION
FOR STAY OF ORDER OF
Pursuant to Rule 6(a) of the Massachusetts Rules of Appellate Procedure, Plaintiff/Appellant Brian Meuse moves this court to stay pending appeal the entire Order of the Essex County Probate & Family Court, Essex County Division at Lawrence. dated 11 October 2000 (Manzi, J.) in the case of Brian Meuse v. Susan Pane. As grounds for this motion,
Meuse states that the court's Order puts the child in harm's way, into
the hands of a mother who canceled all but two weeks of appointments for
physical and occupational therapy which an Early Intervention Program prescribed
for his 14-month-old daughter whose motor skills are equivalent to that
of a 5-month old. From preliminary observations by a
WHEREFORE, Brian Meuse prays that this court see how imperative it is that his motion be allowed.
Respectfully submitted,
15 October 2000
CERTIFICATE OF SERVICE |
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APPEALS COURT ESSEX, SS. C.A. NO. ________ ---------------------------------
v. Susan Pane
This petition is comprised of the following sections: (1) Preliminary Statement, (2) Prior Proceedings and Related Facts, (3-6) the four sections mandated by the Standing Order Concerning Petitions to the Single Justice pursuant to G.L. c. 231, sec. 118 (first paragraph). A supporting memorandum of
law and addendum accompany this petition and a certificate of service is
at the end of each pleading.
1. PRELIMINARY STATEMENT The judge's Order has put the infant in harm's way [Add. 1]. A year ago, mom had absconded with the 2-month-old child to Florida from Massachusetts. Last week, during visitation, dad took the child from Florida back to Massachusetts. On 11 October 2000, the parents were in court for a hearing on emergency motions by both sides. Mom wanted to suspend dad's visitation. Dad wanted custody of the 14-month-old child who cannot crawl or walk or hold a spoon, so that she could be properly diagnosed and treated. [Add. 67ff.] Dad has alleged that mom
is a prescription-drug abuser, and can prove it: mom's health insurer has
produced evidence that mom purchased approximately 70 prescriptions' worth
of drugs before, during, and after her pregnancy [Add. 41-52]. Mom's
drugs of choice are hydrocodone with acetaminophen (APAP), oxycodone with
acetaminophen -- Schedule III drugs -- and Endocet, a Schedule II drug.
One prescription alone was for 360 addictive Ultram pills to take during
her pregnancy [Add. 42]. While the days' old infant was breast-feeding,
the mom was picking up a few more
Mom claims there is another person in the same town with her name who got the drugs.1 [Add. 95]. 1 Mother's attorney [Ms. X] said this in a conference with the newly appointed counsel for the child on 11 October 2000. The assertion is allegedly supported in Pane's answers to interrogatories, served also on October 11th because Meuse had a motion to compel which was to be heard that day. There, on Add. 97, Pane claims that there is another Susan Pane in the same town at an address which appears in a comprehensive police report, effected using the subject Susan Pane's birthdate and social security number.Formerly a pharmacy technician, mom has conveniently forgotten that to get those narcotics, pharmacies require a birthdate and social security number and the name of mom's health insurer so that they can get paid. When the child was 8 days' old, one nurse noted in the medical record that mom came to the office in crisis and almost dropped the baby [Add. 80]. That was one of the days when mom picked up some oxycodone with acetaminophen [Add. 44]. By the time the child was 10 month's old, the child could not sit up on her own, couldn't crawl, couldn't hold a bottle or a spoon [Add. 33-34, 36]. An Early Intervention program wrote that the child needed two sessions weekly for physical therapy (to be able to sit up and to crawl) and two sessions weekly for occupational therapy (to be able to hold a bottle and a spoon) [Add. 36]. By the time the child was 14 month's old, mom had taken the child for therapy only two weeks and had cancelled all other sessions by 3 August 2000 [Add. 74-79, see 77: "Mother stated to office manager that Marissa would not be attending tx [read therapy] at First Step any more in a telephone call"]. Worried that the child's muscles would atrophy and that her already seriously delayed psycho-motor skills would remain impaired, making it impossible for the child to ever walk, dad sought help from the Probate & Family Court, which had decided Massachusetts had jurisdiction over mom, dad, and the child.2 2 Tuesday, 5 September 2000, Cambridge (Sahagian, J.): Meuse and counsel go with Petition for Writ of Habeas Corpus to Judge Sahagian, because she last ruled on visitation [Add. 19-52, Petition; Add. 53-56, Supporting Affidavit].(The Probate & Family Court has never explicitly given either parent custody . . . although a local district court did give dad temporary custody and a restraining order against mom around the time mom first left for Florida.) [Add. 2a-2b, Haverhill District Court (Herlihy, J.) ]. But despite repeated attempts, the court would not help. Judges refused to hear dad's ex parte petition for a writ of habeas corpus, to allow him to get the child back to the Commonwealth [see note 2, supra]. He brought it secretly because he feared that mom, who had traveled with the child to visit with friends and relatives in New York, would move to still another state if she learned he was seeking permission to bring the child north for diagnosis by Boston's finest medical professionals and assure that she receive whatever treatment they recommended. 3 3 Pediatrician Dr. Normand Tanguay, upon examining the child, told Meuse that although a neurology problem could cause the child's problems, her condition resembled that of the Russian adopted children who had been thrown into a playpen and left there deprived of attention and stimuli, and, like Marissa, suffered motor-skill delays.On 11 October 2000, the court spoke [Add. 1]. Judge Mary McCauley Manzi, of the Manzi family which brought down Judge Troy in the early '70s, [In re Troy, 364 Mass. 15 (1973)], refused to read or listen to dad's attorney's argue regarding his emergency motion for custody and learn about the child's condition. Judge Mary McCauley Manzi threatened to report dad's attorney, the author of this email, to the Bar for being unprofessional -- ostensibly for repeatedly asking the court to hear dad's emergency motion. Judge Mary McCauley Manzi ordered dad to deliver the seriously neglected and deprived child back to mom before the court hears his motion 4 [Add.1]. 4 During a recess, the judge had counsel try to find Meuse and tell him to come to court. Counsel left a message on his and his parents' answering machines. Then the attorney appointed for the child had the police check if anyone was at Meuse's home. He reported his lack of success to the court.A little more than an hour later, Judge Manzi wrote and caused her Order to be given to Meuse's counsel. Counsel received it at exactly 3:20 in the afternoon . . . and the Order required Meuse to comply by delivering the child to Pane by 4 o'clock, forty minutes after the Order issued. Even assuming arguendo that Meuse's counsel knew where Meuse was, it would have been impossible for him to comply with the Order. In a nutshell, placing procedure
over substance, the judge is jeopardizing the health, safety, and welfare
of the child by ordering dad to put his beloved daughter back in harm's
way.
2. PRIOR PROCEEDINGS AND RELATED FACTS The instant case was filed on 13 September 1999. Susan Pane was served in September 1999. [Add. 81, medical record in which Pane discusses a "restraining order" with doctor]. On 4 October 2000, Haverhill District Court (Herlihy, J.) issued a restraining order against Susan Pane. Sometime in October, Pane took the child to Florida from Massachusetts without the consent of either Meuse or any court. On 5 March 2000, the Probate & Family court (Manzi, J.) deemed Massachusetts the home state and decided to exercise jurisdiction. On 5 June 2000, believing the child was going to undergo an examination over several months, the court (Sahagian, J.) allowed Brian Meuse visitation in Florida, allowed him to be present at the examination, and wrote that he had a right to the medical records [Add. 7-8]. (The examination took only one day, and a therapy schedule -- described in the previous section -- was put into place, but mother, Susan Pane, never followed it.) Having seen the physical condition of the child when visiting in Florida in June and the first week of August, Meuse brought an Emergency Motion for Custody on 7 August 2000.5 5 Meuse changed counsel at the end of June. New counsel conducted considerable discovery as to the mother's prescription-drug use and received proof that mother had had roughly 70 prescriptions, many of which were Schedule II, III, and VI drugs; many of the Schedule VI drugs were addictive, e.g., Ultram. Mother's health insurer, Merck-Medco, provided a list of the drugs, including, but not limited to, prescription numbers, dates, quantities, doctor's names.Despite the evidence attached to Meuse's motion, the court (Manzi, J.) (1) declared that there was no emergency, (2) denied Meuse's motion, and (3) allowed Pane's motion for temporary child support. Meuse sent but Pane did not cash the child-support checks.6 6 Pane did not cash the first three checks until after September 11th, when she returned from New York [Add. 60a, signed green Return Receipts for weekly child support checks].Finding that noteworthy, he had the Pane Florida house watched. There was no activity. Suspecting that Pane was no longer in Florida, he both prepared an ex parte Petition for a Writ of Habeas Corpus and sought the therapy records from the child-therapy provider. On Tuesday, 5 September 2000, he brought the petition to Middlesex (Cambridge) Probate & Family Court, where Judge Sahagian, who not only was familiar with the Early Intervention examination but had also authored the visitation order around it, was sitting. She declined to hear it because it was an Essex case. Meuse and his counsel immediately drove to Lawrence, but could not get heard: no judges were on the bench. The next day, he tried again. Meuse was told by Ralph Finck that the judge would not hear the petition because 10 days notice had not been given.7 7Actually, Meuse also had other motions, which had been FAXed and served by first-class mail to opposing counsel, but 10 days had not passed. Meuse was only concerned at that time with getting a hearing for the habeas corpus.Later that day, on September 6th, Meuse's counsel contacted the office of Chief Administrative Justice Sean Dunphy and spoke at length with his assistant, Attorney William Ryan, in an attempt to get an assignment of a special judge to the case. Counsel was told that the Chief could only assign a judge if all the judges in Essex refused to hear the case. On Thursday, September 7th, Susan Pane did not appear for her deposition.8 8 On 29 August 2000, Meuse's counsel sent a Notice of Deposition of SusanPrior to that date, it was clear she would not appear. [Add. 9-18, first of three Motions to Compel to Deposition and correspondence from Stults, Pane's counsel].9 9 From the correspondence, Meuse's counsel knew that Pane had no intention of appearing. Pane's counsel said going from Florida to Massachusetts was too expensive. She did not disclose that Pane was already in New York. but her secretary, Tami Thereault, did. Judge Manzi never acted on the motion.So Meuse's counsel updated her pleadings and filed them on Friday, September 8th, in Salem. Judge Rockett held that this was a Lawrence case and refused to hear argument on the petition for a habeas corpus [Add. 60]. Meuse's counsel notified William Ryan by voice mail but she got no response and no assignment of a judge. On or around Thursday, 14 September 2000, Meuse received the child's therapy records and learned that as of mid-September, Susan Pane had canceled all but two weeks of therapy sessions for the child [Add. 74-79] and that, in fact, on 3 August 2000, Pane had phoned the provider that she would not be bringing the child for therapy again [Add. 77 (last few lines on page)]. Then (1)
relying on the therapy provider's information that Pane had stopped all
therapy, (2) being seriously concerned
about the present and future physical and emotional well-being of the child,
(3) knowing that no court had ever given Pane custody of the
child, and (4) believing he had implied
custody, Meuse took Marissa from Florida on 1 October 2000, the first day
of a court-
Whereupon Pane got a short order of notice for hearing on an emergency motion to suspend visitation. Meuse's counsel had received notice by FAX literally before the session in which Pane's motion for short order was to be heard, and was FAXed the order of court (Manzi, J.) granting Pane and ordering hearing on Wednesday, October 11th. On Tuesday, October 10th, Meuse's motion for a short order of notice on his motions was allowed. On October 11th, the court heard Pane's motion but refused to hear Meuse's because he was not present. Given that all his evidence was documentary, his presence was not required. The court was putting procedure over substance, and putting the child back in harm's way. Meuse himself, personally, had not had notice of the proceeding.10 10 His counsel had last spoken to and seen him and the child on Thursday afternoon of October 5th after the child's appointment with a pediatrician.3. REQUEST FOR INTERLOCUTORY REVIEW The review currently sought is from the order (1) requiring the plaintiff, Brian Meuse, to produce the child to mother, Susan Pane, before the court would either read or listen to Meuse's argument that the child would be in harm's way were the physical custody of her be given to mother,11 11The court gave Meuse's counsel the Order demanding that Meuse produce the child within 40 minutes to her mother . . . despite the fact that counsel had already repeatedly told the court that afternoon that she did not know where he was.(2) the granting of sole legal and physical custody of the child to the mother, (3) the suspension of father's visitation, and (4) the appointment as attorney for the child a man who showed himself to be not only uncaring of the child's best interests but sneaky and less than forthright. 4. STATEMENT OF THE ISSUES 1. Where there was justification for Meuse's fear for the health, safety, and welfare of his daughter, the plain course for him to pursue was to get the child and keep her out of harm's way.5. STATEMENT OF THE SPECIFIC RELIEF REQUESTED Plaintiff Brian Meuse seeks the reversal of the order in entirety. Specifically: 1. if this court does not grant him, at the very least, temporary custody, then Meuse wants the court to hear argument on his motion for custody and not make the hearing contingent upon the prior delivery the child to the mother;6. A COPY OF THE ORDER OF THE TRIAL COURT The order by Probate & Family Court is attached to the petition as part of the addendum, which also contains the following pleadings: 1. Order, 10/11/00 (Manzi, J,) |
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APPEALS COURT ESSEX, SS.
C.A. NO. ________
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v. Susan Pane
1.Where there was justification for Meuse's fear for the health, safety, and welfare of his daughter, the plain course for him to pursue was to get the child and keep her out of harm's way. Assuming arguendo that Brian Meuse had not been awarded physical custody after Judge Herlihy's order expired,1 or did not have implied custody, then the following law would apply: The general notion that conduct which would otherwise bePeople & C. v. Craig et al, 78 N.Y.2d 616, 585 N.E.2d 783, 578 N.Y.S.2d 471 (1991). 1Susan Pane absconded with the child to Florida during the first or"In the older English cases, it was a defense to a criminal charge that a defendant committed an act to save a life or to put out a fire." Id. "Where the defense was permitted in the common law, the cases generally required the existence of an "impending danger, present, imminent and not to be averted." Id., cites omitted. Given the emotional and physical condition of the child Marissa, Brian Meuse's act of removing the child from Florida on October 1st, 2000, would be appropriate under the older English cases, as well as under People v. Craig, supra. Such conduct is necessary as an emergency measure to avoidId. And the requirement that the impending injury must beId. Given that the mother's neglect
of the child was so great that Dr. Normand Tanguay, the pediatrician to
whom Brian Meuse brought his child on 5 October 2000, said she resembled
the Russian children he'd seen who have been adopted and brought to this
country and who had been thrown in a playpen and left there, Meuse was
justified in the action he took, to wit, to remove the child
2 Brian Meuse has a suitable, well-maintained single-family home and isIn defense of Meuse's averments that because of her prolonged and continuous drug abuse, Susan Pane, the child's mother, was unable and failed to provide the minimum degree of care for Marissa and thus impaired the child's emotional and physical health and well being and caused a substantial risk of serious future harm to the child -- to wit, the child not being able to walk soon or far into the future. To Meuse's averments, Susan
Pane only response has been that another person with the same name in the
same town must have been the person who procured all the drug prescriptions
[App. 95]. Nor does she deny the condition of the child as
described by Meuse.
2. Where Meuse's counsel's first duty was to further the administration of justice, which mandates candor toward the court, the court committed reversible error by first chastising Meuse's counsel and then not allowing her client's motion to be heard because he was not present.3 3 Given that the motion judge "came out fighting" onto the bench and im- Com. v. Pavao, 39 Mass.App.Ct. 490, 501-502 (1995), citing In the Matter of Neitlich, 413 Mass. 416, 423 (1992). Clearly, by repeatedly exalting
procedure over substance -- wanting Meuse to give Pane 10 days' notice
when a hearing 10 days later would have been too late: Meuse would not
have had access to the child 10 days later, and the likelihood of Pane
fleeing to another state was great and imminent. In fact, Pane had already
made her way with the child to New York. This fact was confirmed by the
secretary of mother's counsel and Meuse put this fact into
Under the circumstances, the court had a considerable obligation to take cognizance of the continuing danger the child would have suffered if Meuse had not taken her from her mother. [I]t remains the general rule and that a stricter duty of thePridgen v. Boston Housing Authority, 364 Mass. 696, 710 (1974). The court failed in that duty and its nonfeasance and/or misfeasance 4 has hindered Meuse's ability to provide his daughter with the medical and professional therapeutic care he had scheduled for her. See Pavao at 499. 4"[B]y `misfeasance' the defendant has created a new risk of harm to theFurther, Meuse's presence was not even necessary. Adoption of William, 38 Mass.App.Ct. 661, 666 (1995), where exclusion of the father from the closed courtroom during the examination of a social worker on the issue of the mother's fitness did not have due process significance. [See discussion and authorities cited below regarding the closed courtroom.] Putting the child back into the mother's care would also further harm the child: this is a mother whose first obligation was to bring the child to therapy but who, instead, made her own desire for a vacation her top priority.5 5The mother, Susan Pane, was unemployed and therefore had no work fromTaking that vacation and not taking the child to therapy was equivalent to an abandonment of the child, requiring relinquishment of the de facto physical custody. In Re Perales, 52 Ohio St.2d 89, 369 N.E.2d 1047 (1977); In the Matter of Tyler Harrison Ramey, a Minor Child, 1999 WL 1281505 (Ohio App. 4 Dist.).6 6 Inspired or encouraged by the court's injudicious condescension, the so-And under Massachusetts statutory law, Susan Pane does not have a right to custody: . . . that a pattern or serious incident of abuse has oc-G.L. c. 208, sec. 31A, and G.L. c. 209C. sec. 10(e). "It is the duty of the judge to consider the welfare of the child[ren] in reference not merely to the present, but also to the probable future." Rolde v. Rolde, 12 Mass.App.Ct. 398, 403 (1981), Jenkins v. Jenkins, 304 Mass. 248, 250 (1939). But Judge Manzi did not consider the welfare of Marissa. Instead, she said she would not read Meuse's pleadings until Meuse was present, and chastized Meuse's counsel each time she attempted to inform the court of the egregious care to which the child was subjected. This also took place in a closed courtroom, Courtroom 9, because, the judge said, she did not want those persons in Courtroom 10, where the session was being held, to hear what the court had to say. Of course, courtrooms are kept public for a purpose. And given that Meuse's counsel was not allowed to address the issues to the court -- which could have been embarrassing to Susan Pane, who was present -- there was no reason to hold the motion hearing in a closed courtroom. Judge Manzi's agenda was
and is unknown. There was no express agreement or consent by counsel to
a closed courtroom. Nor did the court even request agreement or consent,
as the court should have done. See Com. v. Howard, 46 Mass.App.Ct.
366, 367 (1999). Constitutional considerations are invoked in circumstances
such as these. Foley v. Com., 429 Mass. 496, 498 (1999),
Moreover, it is unlikely that this unfit mother is going to change suddenly her neglectful ways and become a fit mother, and, in fact, the mother never said she would change her way of life. So, for the court not even
to read Meuse's pleadings and consider not only the preponderance but the
extensive and undisputable documentary evidence Meuse produced to the court,
evidence demonstrating not only the mother's unfitness but also the child's
serious physical condition, was reversible error.
3.
Where successive courts would not hear him and DSS could not
Because Susan Pane and the child were residing in Florida, the Massachu- setts Department of Social Services was unable to help him and the child. Given also (1)
that Judge Sahagian, who knew of the need for the Early Intervention examination
and had allowed Meuse to have legal custody, entitling him to medical records
[App. 7-8], was sitting in Middlesex and believed she did not have
jurisdiction over the Essex case while she was sitting in Cambridge, (2)
that Judge Manzi refused to hear Meuse because she saw no emergency, (3)that
Judge Rockett wrote that he would not hear Meuse petition for a habeas
corpus writ because the case was a "Lawrence" case,
It was a case of form or
procedure being exalted over substance. As a general rule, the Court does
not raise procedure over substance. Andrews v. Arkwright Mut. Ins. Co.,
1994 WL 879734 at 4 (Mass.Super. 1994). This was not the time to do it.
4. Where the mother has put her own desires for a vacation over the necessity for the child to receive the therapy prescribed by the Early Intervention program, the father, who has regularly put the child above his own interests, is the more suitable custodian for the child. Where Brian Meuse had been awarded custody on 4 October 1999 as part of a 209A Restraining Order and it was extended until the issue as to whether Massachusetts or Florida had home state jurisdiction was resolved, and Susan Pane never had custody but took the child without the consent of either Meuse or any Massachusetts court, Brian Meuse had implied custody. The child did not fare well in her mother's care. In fact, so acute was Susan Pane's neglect of the child that the child at the age of 10 months, when she was examined by the Early Intervention Program ["EIP"], she was found to have the motor skills of a 5-month old: she could not sit up on her own, she could not crawl, she could not stand up, could not hold a bottle, could not hold a spoon [App. 33-34, 36]. The EIP recommended four therapy sessions a week: two for physical therapy, two for occupational therapy. The mother, Susan Pane, saw fit to take the child only for two weeks for the prescribed therapy between 22 June 2000, when the EIP examination took place, and 1 October 2000, when the child's father, Brian Meuse, began his last visitation in Florida. On 3 August 2000, the mother phoned the therapy provider and canceled all future appointments [App. 77]. The quality of care given by the mother should have been determined by the court before awarding her custody on October 11th. Custody of Zia, Docket 00-P-355 (Appeals Court, October 13, 2000), in which the court wrote: "a parent's role as a primary caregiver `should not be afforded substantial weight without a determination as to the quality of that care'," quoting R.H. v. B.F., 39 Mass.App.Ct. 29, 42 (1995). At 14 months, when Meuse saw her and observed that she still could not sit up on her own (although once seated she will maintain the position), could not crawl, could not walk, could not hold a spoon, he decided to take her from Florida and bring her to Massachusetts for diagnosis and treatment and proper daily care. Given that there has been heretofore no temporary custody order other than that given to the father by Judge Herlihy in Haverhill District Court, it can be deemed that Brian Meuse has had implied custody since then and that the mother has been in contempt of Judge Herlihy's continuing order of custody to Brian Meuse. And given the emotional and
physical condition of the child, it can be concluded that the mother is
unfit to have physical custody and that Brian Meuse is the more suitable
parent and must be given sole legal and physical custody of the child.
Such a resolution is best for the child's health, safety, and well-being.
5.
Where the order to turn over the child and suspend visitation
In Dept. of Public Welfare v. J.K.B., 379 Mass. 1, 3 (1979), the Court wrote: The "loss of a child may be as onerous a penalty as theDept. of Public Welfare v. J.K.B., 379 Mass. at 3, citing, amongst others, Quilloin v. Walcott, 434 U.S. 246, 255, 98 S.Ct. 549, 54 L.Ed.2d 511 (1978); Stanley v. Illinois, [405 U.S. 645, 651, 92 S.Ct. 1208, 1212, 31 L.Ed.2d 551 (1972)]; Meyer v. Nebraska, 262 U.S. 390, 399, 43 S.Ct. 625, 67 L.Ed. 1042 (1923). Before the State "deprive(s) a legitimate (Sic) parent of allDept. of Public Welfare v. J.K.B., 379 Mass. at 3-4. August, September, and particularly October, on the 11th, were meaningful times for a meaningful manner. Meuse's presence was not necessary. The evidence was from Susan Pane's health insurer and from the infant's medical and therapy records. Meuse could not have testified to those documents. Those documents provided sufficient evidence for the court to decide short of trial the issue, at the very least, of temporary custody. The chance of error based on the reliable documentary evidence was very slim. In any case, it was appropriate for the court to have erred on the side of caution in the interest of the infant's health, safety, and welfare. Under these circumstances, consideration of the significant medical and therapeutical evidence would have met constitutional requirements of procedural due process. Goldberg v. Kelly, supra. Recognition of important parental rights does not change theDept. of Public Welfare v. J.K.B., 379 Mass. at 5, cite omitted. "`The rights and needs of the child must be considered as well.'" Id, cites omitted. Purinton v. Jamrock, 195 Mass. 187, 199-201 (1907). They were not so considered in the courtroom of Judge Manzi. "When a child's life is at issue, `it is not the rights of the parents that are chiefly to be considered. [Her] first and paramount duty [was] to consult the welfare of the child.'" Custody of a Minor, 375 Mass. 733, 749, quoting Purinton 195 Mass. at 199. 6.
Where the attorney appointed by Judge Manzi to be the child's
Where the attorney appointed
by Judge Manzi to be the child's attorney did not consider either the emotional
and physical well-being of the child, or the failure of the mother to provide
the therapy which had been prescribed by the Early Intervention Program,
the appointment must be vacated. The "child's attorney"
It was a truly sad display of overreaching. (Unfortunately there was insufficient time to obtain the tape of the hearing before the filing of this interlocutory appeal.)
Respectfully submitted,
16 October 2000
_____________________________
CERTIFICATE OF SERVICE
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