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Welcome to the Alternative Commitment and Registration Support Unit’s SDP Documents Bank. The briefs, memoranda, pleadings, clinicians' reports, etc., below were forwarded by SDP panelists and others to us in the hope that they will be of assistance to defense counsel. Their contributions are greatly appreciated.
Copies of the following documents are available (by email request) to defense counsel ONLY. When requesting copies, please identify yourself and your affiliation. Please let us know of any documents you come across that would be helpful to others. Thank you. |
MOTIONS
Copies of the following motions are available (by email request) to defense counsel ONLY. When requesting copies, please identify yourself and your affiliation. |
ISSUE |
ATTORNEY |
Motion to Dismiss - Failure to Timely File [& Memo] |
Bill Robinson |
Motion to Dismiss - Defendant Civilly Committed under G.L. c. 123 [& Memo] |
Mark Gillis |
Motion for Directed Verdict - Insufficiency of Evidence |
Mike Farrington |
Motion for Judgment of Dismissal - No Commonwealth expert [& Memo] |
Mike Farrington |
Motion to Exclude - Hearsay |
David Hirsch |
Motion to Exclude - Police Reports & info therein [& Memo] |
Anna Lembo |
Motion to Exclude - Phallometric result [& Memo] |
Anna Lembo |
Motion in Limine to Exclude - Risk Assessment Testimony (U.S. v. Haynes) |
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Motion to Exclude - Daubert Challenge re Risk Assessment |
David Hirsch |
Motion for Interrogatories & Production of Records |
John Swomley |
Motion for Interrogatories & Depositions |
Greg Bal |
Motion for Speedy § 9 Hearing |
David Hirsch |
MEMORANDA
Copies of the following memoranda are available (by email request) to defense counsel ONLY. When requesting copies, please identify yourself and your affiliation. |
ISSUE |
ATTORNEY |
Support of Motion to Dismiss (Failure to Timely File) |
Bill Robinson |
Support of Motion for Judgment of Dismissal (No Commonwealth expert) |
Mike Farrington |
Support of Motion to Dismiss (Defendent Civilly Committed under G.L. c. 123) |
Mark Gillis |
Support of Motion to Exclude (Police Reports & info therein) |
Anna Lembo |
Support of Motion to Exclude (Phallometric results) |
Anna Lembo |
Support of Request for Daubert/Lanigan Hearing re Risk Assessment |
David Hirsch |
Challenge to St. 2004, c. 66 (Additional "sex offenses" & "repeal" of McLeod) |
David Hirsch |
Admissibility of Reports under G.L. c. 123A, § 14(c) [Confrontation/Crawford] |
David Hirsch |
Admissibility of Reports under G.L. c. 123A, § 14(c) [Bradway] |
David Hirsch |
Imminent Danger of Re-offense |
David Hirsch |
SDP Commitment while Serving Sentence |
David Hirsch |
Failure to Conduct Timely PC Hearing |
David Hirsch |
Right to Interrogatories & Depositions |
David Hirsch |
Validity of Long-Term Risk Assessments |
David Hirsch |
Nexus between Risk and Abnormality/Disorder |
David Hirsch |
Support of Motion for Speedy Hearing - § 9 |
David Hirsch |
Diagnosis of "paraphilia—N.O.S.—rape" not scientifically valid |
David Hirsch |
Antisocial Personality Disorder |
David Hirsch |
Criminal Responsibility & Serious Difficulty in Controlling Behavior |
David Hirsch |
QUALIFIED EXAMINER REPORTS
Copies of the following reports are available (by email request) to defense counsel ONLY. When requesting copies, please identify yourself and your affiliation. |
We now have, in hard copy, reports drafted by the following Qualified Examiners:
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Leonard Bard, Ph.D. |
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Eric Brown, Psy.D. |
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Stephen DeLisi, Ph.D. |
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Carol Feldman, Ph.D., J.D. |
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Robert Joss, Ph.D. |
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Frederick Kelso, Ph.D. |
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Cornelius Kiley, Ph.D. |
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Manju Vachher, Ph.D. |
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Paul Zeizel, Psy.D. |
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QE Ira Silverman's methodology re risk assessment found not reliable; excluded. Commonwealth v. Rajani (9/18/03) |
CLINICIANS' TRANSCRIPTS
Copies of the following transcripts are available (by email request) to defense counsel ONLY. When requesting copies, please identify yourself and your affiliation. |
CLINICIAN |
PROCEEDING |
JURISDICTION |
DATE |
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Howard Barbaree, Ph.D. |
Trial |
CA (Superior Court) |
May 2004 |
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Deposition |
IA |
May 2004 |
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Terence Campbell, Ph.D. |
Daubert/Frye Hearing |
IA (District Court) |
June 2000 |
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Dennis Doren, Ph.D. |
Deposition |
TX (District Court) |
March 2001 |
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Trial |
IA (District Court) |
July 2001 |
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Deposition |
WA (Superior Court) |
April 2002 |
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Trial |
FL (Circuit Court, 2nd District) |
January 2003 |
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Trial |
CA (Superior Court) |
May 2004 |
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Douglas Epperson, Ph.D. |
Deposition |
TX (District Court) |
March 2001 |
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Daubert/Frye Hearing |
IA (District Court) |
June 2000 |
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Karl Hanson, Ph.D. |
Deposition |
TX (District Court) |
November 1999 |
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Stephen Hart, Ph.D. |
Daubert Hearing |
TX (District Court) |
March 2001 |
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Deposition |
FL (12th Circuit) |
April 2001 |
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Harry Hoberman, Ph.D. |
Deposition |
IA (District Court) |
Sept. 2001 |
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Trial |
IA (District Court) |
Nov. 2001 |
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Debra Inman, Ph.D. |
Trial |
CA (Superior Court) |
July 1999 |
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Charles Jackson, Ph.D. |
Deposition |
CA (Superior Court) |
July 2001 |
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P.C. Hearing |
CA (Superior Court) |
March 2000 |
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Douglas Korpi, Ph.D. |
Trial |
CA (Superior Court) |
April 1999 |
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Wesley Maram, Ph.D. |
Deposition |
CA (Superior Court) |
July 2001 |
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Lynn Maskel, M.D. |
Deposition & Daubert Hearing |
TX (District Court) |
March 2001 |
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Daubert/Frye Hearing |
IA (District Court) |
June 2000 |
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Trial |
IA (District Court) |
July 2001 |
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Craig Monroe, Ph.D. |
Trial |
IA (District Court) |
July 2000 |
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Deposition |
IA (District Court) |
January 2003 |
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Randy Otto, Ph.D. |
Daubert Hearing |
TX (District Court) |
March 2001 |
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Robert Owen, Ph.D. |
P.C. Hearing |
CA (Superior Court) |
March 2000 |
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Gabrielle Paladino |
P.C. Hearing |
CA (Superior Court) |
November 2001 |
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Amy Phenix, Ph.D. |
Deposition |
TX (District Court) |
March 2001 |
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