Attorney Document Submission Protocol
Forensic Evaluations
This protocol applies to attorney-submitted documents — materials counsel chooses to submit for Dr. Long’s consideration. Records and collateral interviews requested by Dr. Long as part of the evaluation are handled separately and are not subject to this protocol.
Submission Windows
| Window | Deadline | Purpose |
| Initial Submission | Before the first Diagnostic Clinical Interview (DCI) | Records and materials counsel wants Dr. Long to consider as part of her review |
| Supplemental Submission | Deadline set by Dr. Long | Additional materials that became relevant during the evaluation process |
One supplemental submission is permitted per party. The deadline will be communicated by Dr. Long based on the progress of the evaluation. No further submissions will be accepted after the supplemental deadline, except by agreement of all parties or court order.
Format Requirements
Each submission must include two things: the documents themselves, and an index.
1. Documents
Each item should be a separate file, numbered sequentially and named using this format:
[Number] - [Neutral Description].[ext]
| Correct | Incorrect |
| 01 - CPS Investigative Summary 2024-03-15.pdf | CPS report proving abuse.pdf |
| 02 - Wake County DSS Home Study 2023-11-20.pdf | DSS Report.pdf |
| 03 - Text Messages Between Parties Oct 2024.pdf | Texts showing her lies.pdf |
| 04 - Dr. Martinez Treatment Notes 2024-01.pdf | Scan_20240315 (2).pdf |
File names should be neutral and descriptive. Advocacy language in file names is not appropriate for materials submitted to a forensic evaluator.
2. Index Document
Each submission must include a single index document (Word or PDF) that lists every numbered item with the following information:
| # | Document Description | Counsel’s Stated Relevance to Referral Scope |
| 01 | CPS Investigative Summary by Investigator J. Williams, Mecklenburg County DSS, March 2024 | Agency substantiated neglect finding based on unsupervised minors and inadequate nutrition in the home during respondent’s custodial time |
| 02 | Home Study by Social Worker M. Chen, Wake County DSS, November 2023 | Third-party observation documenting illicit substances within the child’s reach and absence of age-appropriate sleeping arrangements in the home |
| 03 | Text message exchange between parties regarding custody schedule, October 2024 | Respondent cancelled four consecutive scheduled custodial weekends and did not offer make-up time |
| 04 | Individual therapy treatment notes, Dr. R. Martinez, PhD, January 2024 | Respondent disclosed active methamphetamine use during treatment sessions occurring within the evaluation period |
The description should identify what the document is, who created it, and when — enough for the evaluator to understand what she is looking at before opening the file.
The relevance column is counsel’s stated reason for submitting the document — specifically, how it connects to the referral questions or evaluation scope defined in the court order. This is not a place to argue the facts or state what the document “proves.” Think of it as: why does the evaluator need to see this, given the questions she has been asked to answer?
How to Submit
Send a download link (Box, Dropbox, Google Drive, or similar) to the case communication email thread. The link should contain:
- The numbered document files
- The index document
Please do not submit documents individually by email attachment or through the client intake portal.
Equal Access
Dr. Long does not consider documents submitted by one party unless the other party has been provided equal access to the same materials. Because submissions are made to the case communication thread — which includes all counsel of record — this requirement is satisfied at the time of submission. Counsel is responsible for reviewing materials submitted by the opposing party through that thread.
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