(Case Caption)

September 9, 1988

MOTION FOR AUDIOTAPING AND VIDEOTAPING OF ALL
ADULT INVESTIGATIVE CONTACTS WITH THE MINOR CHILD

The defendant, through his attorneys, hereby moves this Court for an Order requiring that all adult investigative contacts with the minor child concerning allegations of sexual abuse of the minor child by the father, including but not limited to investigative contacts by Court appointed professionals, law enforcement personnel, Department of Child and Youth Services, and the Family Relations Office, must be audiotaped and/or videotaped, duplicate tapes to be provided to all parties within three days of each investigative contact, and that each and every audiotape and/or videotape heretofore made involving the minor child shall be preserved, duplicates provided to all parties within one week of the granting of this motion, and the originals deposited with the Court within one week of the granting of this Motion.

 

THE DEFENDANT

 

by _____________________
           His Attorney

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