Brief Bank (Still under construction with links to material on the old webpage)

Welcome to the Mental Health Litigation Division’s Brief Bank.  The documents below were drafted by mental health panelists for use in their cases and forwarded to us with the hope that they will be of assistance to others.  Their contributions are greatly appreciated.  If you have any briefs, memoranda, pleadings, etc. that would be of interest/assistance to your colleagues, please forward copies (preferably by email) to us, redacted to maintain client confidentiality.

Thank you.

Substituted Judgment-DNR Orders

see also: Findings & Order
Memorandum Robert Weber 
§ 7: Dismiss Petition – “Patient” of facility

see also: Findings & Order
Motion &
Robert Weber
§ 9(b): Condtions of Discharge
Motion for
Richard Ames
§ 9(b): Change of Venue
Richard Ames
Relief from Order of Commitment Motion Stan Goldman
§ 9(a): Insufficient Evidence to Commit Brief Stan Goldman
Criteria to Commit Trial
Stan Goldman
§ 18 Observation: Interlocutory Relief Petition Stan Goldman
Relief Pursuant to G.L. c. 211, § 3 Petition
to SJC
Stan Goldman
Motion for Funds: Appeal of Denial Amicus Brief Stan Goldman
Motion for Funds: Appeal of Denial Memo Laura Sanford
§ 9(a): Appeal of Denial of Motion to Dismiss
[14-day Rule]
Brief John Nicholson
& Jennifer Honig
Motion to Vacate Order of Commitment Motion Stan Goldman
Motion to Dismiss: Late Faxing of Petition Memorandum Peter F. Kuntz
Motion to Exclude Hearsay Police Reports Motion Kerry Kotar