Free Order - District Court of Connecticut - Connecticut

Case 2:89-cv—00859-AHN Document 523 Filed 07/12/2006 Pagé l of 4
UNITED STATES DISTRICT . ..
DISTRICT OF CONNECTICPTE 2 -‘.._ __ _a
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Plaintiffs, : Mr, .T
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v. ; 6 l Ein/it' No. Has-ssa
(AHN)
M. I ODI RELL, g al,
; JZ/5, 7 , 2006
Defendants. :
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STIPULATED MODIFICATION
TO THE REVISED EXIT PLAN OF JULY 1 2004

The parties, by their undersigned counsel, hereby stipulate and agree to the
following modifications to the Revised Exit Plan dated July 1, 2004:
l. Outcome Measure 3: Treatment Plans, shall be modified to state as follows:
In at least 90% of the cases, except probate, interstate, and subsidy only cases,
appropriate treatment plans shall be developed as set forth in the "DCF Court
Monitor’s 2006 Protocol for Outcome Measures 3 and l5" dated June 29, 2006,
and the accompanying "Directional Guide for OM3 and OMl5 Reviews" dated
June 29, 2006.
2. Outcome Measure 15: Childrens’ Needs Met, shall be modified to state as
follows:
At least 80% of all families and children shall have all their medical, dental,
mental heath and other service needs met as set forth in the "DCF Court
Mor1itor’s 2006 Protocol for Outcome Measures 3 and l5" dated June 29, 2006,
and the accompanying "Directional Guide for OM3 and OM15 Reviews" dated
June 29, 2006.
3. The DCF Court MOHltOI,S 2006 Protocol for Outcome Measures 3 and 15 dated
June 29, 2006, is attached as Exhibit A to this Stipulation.

l
‘ /2006 Pa e 2 ot 4
Case 2:89-cv—00859-AHN Document 523 Flléd 07/12 g
4. The Directional Guide for OM3 and OM] 5 Reviews dated June 29, 2006, is
attached as Exhibit B to this Stipulation.
5. Pages 8, 9, 10, and ll ofthe Revised Exit Plan dated July l, 2004, concerning
Outcome Measure 3, shall be replaced with such pages as attached as Exhibit C to this
Stipulation.
6. Pages 25 and 26 of the Revised Exit Plan dated July 1, 2004, concerning Outcome
Measure 15, shall be replaced with such pages as attached as Exhibit D to this
Stipulation.
7. Pages 5, 6 and 7 of the Appendix: Research Questions, Logic, Measurement
Elements and Identified Variables for Revised Exit Plan of July 1, 2004, concerning A
Outcome Measure 3, shall be replaced with such pages as attached as Exhibit E to this
Stipulation.
8. Pages 21 and 22 of` the Appendix: Research Questions, Logic, Measurement
Elements and Identified Variables for Revised Exit Plan of July l, 2004, concerning
Outcome Measure 15, shall be replaced with such pages as attached as Exhibit F to this
Stipulation.
9. Page 4, paragraph 9 ofthe Revised Exit Plan of July 1, 2004, shall be modified to
state as follows:
The Court Monitor will conduct case reviews to produce annual reports
documenting the Department of Children and Families’ performance and
progess toward achieving the outcome measures defined within this Exit
Plan, except Outcome Measures 3 and 15, for which there will be separate
quarterly case record reviews. The annual report concerning 2006 data
will include a synopsis of the quantitative data provided by DCF in the
third and fotuth quarters of the calendar year of 2006, as well as the
quantitative and qualitative findings from the research questions
documented in the attached addendtun document. This report will be tiled
with the Court in April of 2007. Subsequent annual reports will include a q
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Case 2:89-cv—00859-AHN Document 523 Filed 07/12/2006 Page 3 of 4
synopsis of the quantitative data provided by DCF, as well as the
quantitative and qualitative findings for those subsequent calendar years
from the research questions doctunented in the attached addendum
document.
10. Page 4 of the Revised Exit Plan of July 1, 2004, shall be modified to include a
new paragraph 10 that shall state as follows:
Until jurisdiction over this matter is terminated by the Court, the parties
agree that the DCF Court Monitor shall have discretion to conduct
and provide for such additional reporting and case reviews that are
consistent with the terms of the Revised Exit Plan of July 1, 2004, as
modihed, and under any other applicable Cotu·t orders.
11. Page 4 of the Revised Exit Plan of July 1, 2004, shall be replaced with such page
as attached as Exhibit G to this Stipnlation.
RESPECTFULL SUBMITTED,
BY:
te en Frederick
Federal Bar No. c 08743
strederick@[email protected]
Wofsey, Rosen, Kweskin & Kurlansky, LLP
600 Summer Street
Stamford, CT 06901-1490
Tel (203) 327-2300
Fax (203) 967-9273
Marcia Robinson Lowry
Federal Bar No. ct04688
mlog5,;(@childrensrigl;ts.org
Ira P. Lustbader
Federal Bar No. ct23551
ilustbader@childrensri ghtsorg
Children’s Rights
330 Seventh Avenue, 4th Fl.
New York, NY 10001
Tel 212—683—2210
Fax 212-683-4015
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Case 2*89-cv—00859-AHN Document 523 Filed 07/12/2006 Page 4 Of 4
FOR FLAINTIFF S
BY: dawg. (amy 4/so/aa
Ann H. Rubin, Esq.
Federal Bar No. ctO4486
BI'L}.b1I1@C3ImOdy1&W.COm
Carmody & Torrance LLP
195 Church Street
New Haven, CT 06590-1950
Tel (203) 777-5501
FOR DEFENDAN TS
SO ORDERED:
- _ *7 L D (__
Hon. Alan H. Nevas, SeEor U.S.D.J. DATE [
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