(Case Caption)

September 9, 1988

MOTION FOR COURT APPOINTED INDEPENDENT
PSYCHOLOGICAL EVALUATION OF THE MINOR CHILD
AND FOR ELECTRONIC RECORDING OF INTERVIEWS

The defendant, through his attorneys, hereby moves this Court for an Order requiring the minor child, Steven Ferguson, to undergo a psychological evaluation by an independent, Court appointed psychiatrist or clinical child psychologist with training and experience in evaluating claims of child sexual abuse, and further ordering that all interviews be audiotaped, and that each interview which is intended to explore the topic of sexual abuse be videotaped, with duplicate audio- and videotapes of all sessions to be made available to the respective parties at their expense within two weeks of each interview, and the original tapes to be preserved by the evaluator until further order of the Court.

 

THE DEFENDANT

 

by _____________________
           His Attorney

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