IN THE CIRCUIT COURT OF CARROLL COUNTY, ARKANSAS
JUVENILE DIVISION
ARKANSAS DEPARTMENT
OF HUMAN SERVICES
vs.
PLAINTIFF
No. JV 2010-84 ED
___________________________
(Mother)
___________________________
(Father)
___________, a minor child
DOB 11/22/10
DEFENDANT(S)
PETITION FOR SERVICES
COMES NOW ___________, husband and wife, and state the following:
1. They are the legal parents of David ____ an infant child currently in the legal
and physical custody of the Department of Human Services.
2. _________ is a disabled person, who receives disability benefits from the
Social Security Administration for mild developmental disabilities, or, as designated by
the listed impairment, Mental Retardation.
3.
_________ is therefore in the category of persons protected by Title II of the
Americans with Disabilities Act, 42 U.S.C. 12101-12213. She is entitled to reasonable
accommodation of her disability in the provision of state services.
4.
The parents in this case have been provided generic reunification services,
which have not been related to the specific disability of ________. In order to
accommodate the disability of _________, and in order to facilitate the reunification of
_________ with his parents, petitioners request the following targeted actions and
services:
(a) Coordination with and referral to The Department of Human Services
Developmental Disabilities Division, more specifically, the part C early intervention
program, which provides services for parents and children with developmental
disabilities, and programs to enhance the capabilities of children and families with
developmental disabilities.
(b) DCFS should be ordered and directed to contract with the Carroll County
Learning Center in order to provide qualified behavior and learning specialists, who are
trained in working with the mentally retarded, to assist the family in obtaining parenting
skills, and to identify and provide the family with relevant learning materials directed to
persons with cognitive disabilities.
(c) DCFS should identify resources for day care assistance with David during the
day when Mr. ____ is at work, and/or in the initial stages of home visits prior to a
temporary home placement.
(d) DCFS should promptly institute in home visitation and educational services
conducted in the most homelike atmosphere practicable.
(f) DCFS should make inquiry and report to the Court on the availability of
Medicaid Waiver Services to provide care for family members in the home.
(g) DCFS, in conjunction with the Developmental Disability Section of the
Department of Human Services, should provide targeted, intensive, in-home services for
90 days, including training and assessment in the following areas:
l. Continuation of the family therapy for ______________
2. Individual therapy for ________ to address her fear and resentment over the
removal of her child.
3. Communication skills
4. Anger Management for ______________
5. Crisis intervention services
6. Fiscal and home management skills as needed.
7. Homemaker services with emphasis on the control of allergens.
8. Smoking cessation services if requested by the parents.
9. The development of a permanent safety plan
10. Reading infant cues and learning signals.
11. Cognitive and behavioral training as necessary.
12. Responding to emergencies, and first aid.
13. Age appropriate CPR
14. Provision of home safety supplies, and emergency breathing apparatus.
15. Menu Planning
16. Simple and instructive texts or videos relating to disciplinary strategies, home
safety hazards, recognizing illness, infant stimulation and responsiveness and
emergencies.
17. Provision of air purifiers in the residence if needed.
WHEREFORE, petitioners pray for the services requested above, and for any and
all additional services to accommodate the disability of _________, and to accomplish
the stated goal of reunification of the child with his parents.
___________________________________
MARGARET REGER,
Attorney for ______________________
Legal Aid of Arkansas
816 North Main Street
Harrison, Arkansas 72601
Telephone: (870) 741-2454, or
1-800-967-9224, Ex. 5302
Facsimile: (870) 741-4255
mreger@arlegalaid.org
CERTIFICATE OF SERVICE
On this 3rd day of November ,2011, I delivered the foregoing pleading in open
court to the following persons:
1.
2.
Tammy Mullins, AAL for David Spall
Robert Depper, Attorney for Arkansas Department of Human Services