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Case 2:89-cv—00859-AHN Document 520 Filed 07/10/2006 age 0
UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT tf; §
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Plaintiffs, :
: ` . HEQIFCE YI
v. : CIVIIJTNO-i'»HS9¥859
(AHN)
M. Joortusu., q at, J
; JW? 7 , 2006
Defendants. :
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STIPULATED MODIFICATION
TO THE REVISED EXIT PLAN OF JULY 1 2004

The parties, by their undersigned cotmsel, hereby stipulate and agree to the
following modifications to the Revised Exit Plan dated July 1, 2004:
I. 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 I5" dated June 29, 2006,
and the accompanying "Directional Guide for OM3 and OMl5 Reviews" dated
June 29, 2006.
2. Outcome Measure I5: 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 C ourt
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.
3. The DCF Court Monitor’s 2006 Protocol for Outcome Measures 3 and I5 dated
June 29, 2006, is attached as Exhibit A to this Stipulation.

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Case 2:89-cv—00859-AHN Document 520 Filed 07/10/2006 Page 2 of 4
4. The Directional Guide for OM3 and OMl5 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 1, 2004, conceming
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
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 of the Revised Exit Plan of July 1, 2004, shall be modiiled to
state as follows:
The Court Monitor will conduct case reviews to produce annual reports
documenting the Department of Children and Families’ performance and
progress 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 fourth quarters of the calendar year of 2006, as well as the
quantitative and qualitative findings from the research questions
documented in the attached addendum document. This report will be filed
with the Court in April of 2007. Subsequent annual reports will include a
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Case 2:89-cv—00859-AHN Document 520 Filed 07/10/2006 Pagé 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 documented 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
modified, and under any other applicable Court orders.
1 1. Page 4 ofthe Revised Exit Plan of July 1, 2004, shall be replaced with such page
as attached as Exhibit G to this Stipulation.
RESPECTFULL SUBMITTED, )
BY:
te en Frederick
Federal Bar No. c 08743
[email protected]
Wofsey, Rosen, Kweskin & Kuri ansky, LLP
600 Summer Street
Stamford, CT 06901-1490
Tel (203) 327-2300
Fax (203) 967-9273
——and—
Marcia Robinson Lowry
Federal Bar No. ct04688
[email protected]
Ira P. Lustbader
Federal Bar No. ct23551
ilustbader@childrensrightsorg
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 520 Filed 07/10/2006 Page 4 Of 4
FOR PLAIN TIFFS
BY; 6//=?¤/oo
Ann H. Rubin, Esq.
Federal Bar N0. ct04486
[email protected]
Carmody & Torrance LLP
195 Church Street
New Haven, CT 06590-1950
Tel (203) 777-5501
FOR DEFENDAN TS
SO ORDERED:
Hon. Alan H. Nevas, Senior U.S.D.J. DATE
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