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9. Obtain all documents and information needed, including copies of all <br />pleadings and relevant notices filed by other parties; <br />10. Participate in all depositions, negotiations, discovery, pretrial conferences, <br />mediation sessions (when appropriate), and hearings; <br />11. Participate in settlement negotiations and attempt speedy resolution of the <br />case, when appropriate; <br />12. Develop a case timeline and tickler system; <br />13. Subpoena and prepare all witnesses, including the client; <br />14. Ensure proper notice is provided to all parties and necessary caretakers; <br />Hearings <br />15. Attend and prepare for all hearings; <br />16. Prepare and make all appropriate motions and evidentiary objections; <br />17. Present case in chief, present and cross-examine witnesses, prepare and <br />present exhibits; <br />18. In jurisdictions in which a jury trial is possible, participate in jury selection <br />and drafting jury instructions; <br />19. Request the opportunity to make brief opening and closing arguments when <br />appropriate; <br />20. Prepare or help prepare proposed findings of fact, conclusions of law and <br />orders when they will be used in the court's decision; <br />Post Hearings/Appeals <br />21. Follow all court orders pertaining to the attorney for the client/agency; <br />22. Review court orders to ensure accuracy and clarity and review with agency <br />when necessary; <br />23. Take reasonable steps to ensure the agency complies with court orders; <br />24. Consider and discuss with the agency the possibility of appeal; <br />25. If a decision is made to appeal, timely file the necessary post-hearing motions <br />and the notice to appeal paperwork; <br />26. Request an expedited appeal, when feasible, and file all necessary paperwork <br />while the appeal is pending; <br />27. Communicate the results of the appeal and its implications to the <br />agency/client. <br />Commentary: This list is not comprehensive but includes key aspects of the agency <br />attorney's role. The agency attorney has many tasks to perform. An initial section of <br />any standards should define these responsibilities. <br />,, <br />~..`7 `- <br />