A prosecutor has an aggravated sexual assault of a child case in which the defense has issued a subpoena duces tecum for the school counselor�s notes and any CPS investigator�s notes. The prosecutor would like an example of a motion allowing the court to quash the subpoeana or, in the alternative, to order the records be produced in camera for inspection, etc., per Family Code Sec. 261.201 (re the CPS records). If you have one you would be willing to share, please email it to me so that I can forward it to the requesting prosecutor.

Thanks!
-Shannon