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MOTION FOR AUDIO RECORDING IN LIEU OF STENOGRAPHIC RECORDING OF ALL PROCEEDINGS
 
 
 

MOTION FOR AUDIO RECORDING IN LIEU OF STENOGRAPHIC RECORDING OF ALL PROCEEDINGS

Pursuant to Rule 30.02(4)(a) of the Rules of Civil Procedure.

Come now the Respondents, by and through their attorney, _________________ and would show the court as follows:


1. The Respondents have been declared indigent and partially indigent in the past and appointed Counsel of ______________ in the above styled matters.

2. The Respondents wish to preserve their U.S. Constitutional and Tennessee Constitutional rights by preserving all proceedings, fully and accurately.

3. The Respondents have heretofore filed a Motion to Engage the Services of a Court Reporter.

4. In the aforementioned Motion, Respondents asked the Court to authorize the engagement of a Court Reporter with the State bearing the cost.

5. Aforementioned Motion was denied.

6. Respondents can not, due to lack of funds, engage the services of a Certified Court Reporter to fully, adequately and accurately maintain the proceedings.

7. Respondents have available to them, an electronic audio recording device.

8. ______________, attorney for Respondents is a Notary Public and able and authorized to take oaths.

9. Respondents are prepared to record, with said electronic audio recording device, all proceedings.

10. Respondents are prepared to provide copies of all proceedings to Petitioners, at cost, a full and complete copy of such recordings.


Premises above considered, the Respondents pray as follows:


A. That the Court allow all proceedings to be recorded by Respondents via electronic audio recording device.

B. That the Respondents have such further and other relief as may be their just due under the facts and circumstances of this case.

Respectfully Submitted,



CERTIFICATE OF SERVICE



I, ATTY NAME, do hereby certify that an exact copy of this document has been delivered, via______________________________________________________________ to ____________________, Attorney for the Department of Children's Services, ____________________________, Attorney ______________, Guardian ad litem, ______________________________,

this the day of ______________, 200___.