{
  "generated": "2026-08-20",
  "version": "V44",
  "classification": "Public-safe source-navigation edition; not a court ruling or disciplinary finding.",
  "five_issue_matrix": [
    {
      "Live issue / order term": "A. Reasonable daily electronic contact Order: opportunity for reasonable daily contact by telephone, video, gaming platform, or other media, at reasonable times convenient to the child. [S1]",
      "Plaintiff's implementation request": "Current number and platform; recurring contact window; adult-supported availability; reasonable schedule exceptions; same-day or next-day fallback; no compelled conversation. [S2, S11]",
      "Bedard / client written position": "Feb. 16: Bedard deferred contact logistics to Morse. Mar. 18 and Apr. 6: child determines contact / cannot be forced. Apr. 21: contact information had been provided, but child could not be forced to engage. [S3-S6]",
      "Documented status": "A phone number was eventually confirmed. The Aug. 7 Motion alleges that no dependable recurring opportunity or fallback was established and that permission to send messages was treated as the practical implementation. [S11]",
      "Questions remaining for October 8": "What recurring opportunity actually existed? Who supported it? What fallback applied? What attempts succeeded or failed? Was child preference used to eliminate the opportunity itself rather than merely the conversation?",
      "Best proof / likely witness": "Native emails; phone/text/video logs; Morse; Plaintiff. Bedard testimony ordinarily unnecessary unless he offers firsthand facts beyond the emails."
    },
    {
      "Live issue / order term": "B. Compliance with paragraphs 1-3 before in-person progression Order: in-person contact contingent on Plaintiff's compliance with therapy, treatment/evaluation, and electronic-contact paragraphs. [S1]",
      "Plaintiff's implementation request": "Identify every allegedly unmet condition; identify requested proof; provide a neutral, confidential submission/review process; state what would trigger progression. [S8, S11]",
      "Bedard / client written position": "Mar. 18: \"no proof\" of completion. Apr. 21: proof must be provided and \"Amanda and I will review\" whether it meets the Order. [S4, S6]",
      "Documented status": "The Aug. 7 Motion alleges that no court-controlled procedure resolved what remained unmet, what proof was required, or who had final authority to assess compliance. [S11]",
      "Questions remaining for October 8": "Which specific condition was allegedly unmet on each relevant date? What evidence was requested, received, or rejected? Who made the decision? What nonprivileged criteria were used? Was a confidential neutral review ever proposed?",
      "Best proof / likely witness": "Treatment/evaluation records through a protected process; provider testimony if necessary; filing/service records; Morse. Bedard may become relevant only as to his own nonprivileged review acts or firsthand factual assertions."
    },
    {
      "Live issue / order term": "C. In-person contact progression Order: starting no later than 30 days, subject to compliance, at least two hours over lunch or dinner on at least two days each week, with safeguards. [S1]",
      "Plaintiff's implementation request": "Specific dates, times, locations, transportation, appropriate adult/public-place safeguards, alternatives, and a rolling schedule that respects the child without making him the sole decision-maker. [S8, S11]",
      "Bedard / client written position": "Mar. 18: child would determine what other contact he wanted. Apr. 6: Morse could not force contact and \"nothing more\" could be done. Apr. 21: even if proof met the Order, contact remained doubtful because the child might not agree. [S4-S6]",
      "Documented status": "The Aug. 7 Motion alleges that no recurring paragraph-4 schedule was implemented and no neutral determination resolved the prerequisite dispute. [S11]",
      "Questions remaining for October 8": "Were any qualifying visits offered or completed? What dates and durations? What adult-generated alternatives were proposed? Was the child's preference treated as a practical veto? What exact order language supposedly authorized that result?",
      "Best proof / likely witness": "Calendars; complete email threads; Morse; Plaintiff; Pierce for clinical logistics. Bedard's legal interpretation is in the emails; testimony is needed only if he claims additional firsthand facts."
    },
    {
      "Live issue / order term": "D. Weekly reunification therapy and make-up logistics Order: weekly joint reunification therapy with Daniel Pierce, LCSW. [S1]",
      "Plaintiff's implementation request": "Reliable transport/production responsibility; punctual start and full session; prompt notice; make-up within a definite period when displaced or materially shortened; provider-controlled exceptions. [S2, S11]",
      "Bedard / client written position": "Implementation correspondence repeatedly returned the practical burden to the child or to therapy discussion. The record alleges an Apr. 23-25 displaced session and a May 8 late/shortened session, with no standing make-up protocol. [S8, S9, S11]",
      "Documented status": "No consistent written make-up rule is identified in the current record. Individual counseling availability and direct parent access to relevant provider information also remained disputed. [S8, S9]",
      "Questions remaining for October 8": "What was the complete session calendar? Who transported? Which sessions began late, ended early, or were displaced? What make-up occurred? What did Pierce recommend? Was individual counseling made available and with what access?",
      "Best proof / likely witness": "Pierce scheduling and attendance records; invoices; complete email threads; Pierce; Morse; Plaintiff. Bedard is not the best witness to clinical events."
    },
    {
      "Live issue / order term": "E. Medical, school, records, prompt communication, and child-as-intermediary issues Order: shared rights; access to medical/dental/school records; major-change information; prompt child-related messages; no disparagement. [S1]",
      "Plaintiff's implementation request": "Complete notice with date/time/location/provider; direct school and provider access; releases; insurance/MaineCare information; punctuality plan; adult-only communication of disputed legal restrictions; portal/audit preservation. [S2, S8, S11]",
      "Bedard / client written position": "Apr. 6: obtain school records directly. Apr. 21: Morse would inform Plaintiff when she believed she needed to. July 29: Morse said the PFA barred Plaintiff from attending the Aug. 3 physical; that categorical interpretation was disputed with Bedard copied. [S5, S6, S10]",
      "Documented status": "School records reflected serious tardy/absence totals and a mailing address that Plaintiff states was not his. The July 27 medical notice initially omitted time/location. On Aug. 3 the child said he was \"pretty sure\" Plaintiff should not be there. Portal access and the source of the child's belief remained unresolved. [S9-S11]",
      "Questions remaining for October 8": "Who supplied school contact data? What punctuality plan existed? What provider/dental/insurance records remain missing? What exact PFA provision was relied on? What was communicated to the child and provider? What do portal and demographic audit logs show?",
      "Best proof / likely witness": "School/provider records and custodians; portal audit data; Morse; Plaintiff; Pierce if litigation exposure arose in therapy. Bedard only if he personally communicated a disputed restriction to a third party or offers personal facts not otherwise available."
    }
  ],
  "questions": [
    {
      "No.": "1",
      "Unanswered / disputed question": "What telephone number, platform, and recurring availability window governed reasonable daily contact on each period after February 11?",
      "Why material": "Defines the actual opportunity provided under paragraph 3.",
      "Best source": "S2-S6, S8, phone logs",
      "Counsel-role note": "Documents/Morse first; Bedard testimony not ordinarily needed.",
      "Category": "ELECTRONIC CONTACT"
    },
    {
      "No.": "2",
      "Unanswered / disputed question": "What adult-supported step occurred when no response or connection occurred?",
      "Why material": "Distinguishes an opportunity from permission to send unanswered messages.",
      "Best source": "S8, S11, device logs",
      "Counsel-role note": "Morse/Plaintiff.",
      "Category": "ELECTRONIC CONTACT"
    },
    {
      "No.": "3",
      "Unanswered / disputed question": "What same-day or next-day fallback existed for school, work, driving, sleep, illness, or scheduled activities?",
      "Why material": "Tests whether reasonable flexibility became functional nonavailability.",
      "Best source": "S11; calendars",
      "Counsel-role note": "Morse/Plaintiff.",
      "Category": "ELECTRONIC CONTACT"
    },
    {
      "No.": "4",
      "Unanswered / disputed question": "How many contact attempts and successful contacts occurred, by date and duration?",
      "Why material": "Provides objective implementation data rather than competing generalizations.",
      "Best source": "Call/text/video logs",
      "Counsel-role note": "Records custodian/Plaintiff.",
      "Category": "ELECTRONIC CONTACT"
    },
    {
      "No.": "5",
      "Unanswered / disputed question": "Was the child's preference applied only to timing/frequency, or used to eliminate the adult duty to create a reasonable opportunity?",
      "Why material": "Directly addresses the order-language dispute.",
      "Best source": "S1, S4-S6",
      "Counsel-role note": "Legal issue; emails are primary evidence.",
      "Category": "ELECTRONIC CONTACT"
    },
    {
      "No.": "6",
      "Unanswered / disputed question": "Which exact paragraph 1-3 requirement was allegedly unmet on March 9, March 18, April 21, July 13, and August 7?",
      "Why material": "A private, shifting deficiency cannot operate as an indefinite stay without particularization.",
      "Best source": "S4, S6, S11",
      "Counsel-role note": "Morse; documentary record; Bedard only for his own personal factual assertion.",
      "Category": "COMPLIANCE PREREQUISITES"
    },
    {
      "No.": "7",
      "Unanswered / disputed question": "What proof was requested, when, by whom, and in what form?",
      "Why material": "Tests notice and ability to cure.",
      "Best source": "Email threads; service records",
      "Counsel-role note": "Documents first.",
      "Category": "COMPLIANCE PREREQUISITES"
    },
    {
      "No.": "8",
      "Unanswered / disputed question": "What proof was actually received, and what item was allegedly missing?",
      "Why material": "Separates nonproduction from disagreement about sufficiency.",
      "Best source": "Protected treatment/evaluation records; transmittals",
      "Counsel-role note": "Provider/court process; privilege and confidentiality safeguards required.",
      "Category": "COMPLIANCE PREREQUISITES"
    },
    {
      "No.": "9",
      "Unanswered / disputed question": "Who made the sufficiency determination, and who had final authority?",
      "Why material": "The emails refer to a joint client/counsel review, while the Motion seeks a neutral judicial determination.",
      "Best source": "S6, S11",
      "Counsel-role note": "Potential Bedard issue only as to nonprivileged personal acts.",
      "Category": "COMPLIANCE PREREQUISITES"
    },
    {
      "No.": "10",
      "Unanswered / disputed question": "What nonprivileged criteria were applied in the stated \"Amanda and I will review\" process?",
      "Why material": "Potentially material if counsel intends to defend the enforcement posture through his own review.",
      "Best source": "S6; any written criteria",
      "Counsel-role note": "Possible Rule 3.7 issue if criteria and acts are disputed and unavailable elsewhere.",
      "Category": "COMPLIANCE PREREQUISITES"
    },
    {
      "No.": "11",
      "Unanswered / disputed question": "Was any confidential court-approved or provider-to-provider review proposed before contact progression was withheld?",
      "Why material": "Tests whether privacy and compliance could have been resolved without indefinite delay.",
      "Best source": "Motions, emails, docket",
      "Counsel-role note": "Documents/court record.",
      "Category": "COMPLIANCE PREREQUISITES"
    },
    {
      "No.": "12",
      "Unanswered / disputed question": "On what date would in-person progression begin if the Court found the conditions satisfied?",
      "Why material": "Necessary for a workable order.",
      "Best source": "S1, S3-S6",
      "Counsel-role note": "Legal/operational question.",
      "Category": "COMPLIANCE PREREQUISITES"
    },
    {
      "No.": "13",
      "Unanswered / disputed question": "List every qualifying two-hour visit offered, scheduled, completed, declined, or cancelled after the thirty-day date.",
      "Why material": "Measures implementation against paragraph 4.",
      "Best source": "Calendars, emails, logs",
      "Counsel-role note": "Morse/Plaintiff.",
      "Category": "IN-PERSON PROGRESSION"
    },
    {
      "No.": "14",
      "Unanswered / disputed question": "What dates, locations, transportation arrangements, or appropriate adults did Defendant propose?",
      "Why material": "Tests adult facilitation rather than abstract willingness.",
      "Best source": "Email threads",
      "Counsel-role note": "Morse.",
      "Category": "IN-PERSON PROGRESSION"
    },
    {
      "No.": "15",
      "Unanswered / disputed question": "What public-place, trusted-adult, separate-arrival, or other safeguards were considered?",
      "Why material": "The Order expressly supplied alternatives.",
      "Best source": "S1, S11",
      "Counsel-role note": "Morse/Pierce/Plaintiff.",
      "Category": "IN-PERSON PROGRESSION"
    },
    {
      "No.": "16",
      "Unanswered / disputed question": "What exact order language was relied on to make the child the practical or \"sole\" gatekeeper?",
      "Why material": "Central legal interpretation issue.",
      "Best source": "S1, S4-S6, S8",
      "Counsel-role note": "Documents are primary; not a factual need for counsel testimony.",
      "Category": "IN-PERSON PROGRESSION"
    },
    {
      "No.": "17",
      "Unanswered / disputed question": "When contact did not occur, what replacement opportunity was offered?",
      "Why material": "Relevant to prospective enforcement and replacement contact.",
      "Best source": "Emails/calendars",
      "Counsel-role note": "Morse/Plaintiff.",
      "Category": "IN-PERSON PROGRESSION"
    },
    {
      "No.": "18",
      "Unanswered / disputed question": "Who communicated to the child that in-person contact was optional, prohibited, or dependent on an unresolved adult legal conclusion?",
      "Why material": "Relevant to adult-only implementation and non-disparagement safeguards.",
      "Best source": "Native communications; testimony",
      "Counsel-role note": "Morse/Pierce; Bedard only for any proven direct communication by him.",
      "Category": "IN-PERSON PROGRESSION"
    },
    {
      "No.": "19",
      "Unanswered / disputed question": "What is the complete weekly therapy calendar from February 11 through the hearing?",
      "Why material": "Establishes expected versus actual weekly participation.",
      "Best source": "Pierce records/invoices",
      "Counsel-role note": "Pierce.",
      "Category": "THERAPY AND MAKE-UP LOGISTICS"
    },
    {
      "No.": "20",
      "Unanswered / disputed question": "Who was responsible for transport and production for each session?",
      "Why material": "Identifies operational responsibility.",
      "Best source": "Emails, attendance records",
      "Counsel-role note": "Morse/Plaintiff/Pierce.",
      "Category": "THERAPY AND MAKE-UP LOGISTICS"
    },
    {
      "No.": "21",
      "Unanswered / disputed question": "Which sessions began late, ended early, were displaced, or were missed, and why?",
      "Why material": "Tests recurring implementation failures without inferring motive.",
      "Best source": "Provider records, messages",
      "Counsel-role note": "Pierce.",
      "Category": "THERAPY AND MAKE-UP LOGISTICS"
    },
    {
      "No.": "22",
      "Unanswered / disputed question": "What make-up occurred for the April displaced session and the May 8 shortened session?",
      "Why material": "Directly tests remedy and preservation of court-ordered time.",
      "Best source": "S8, S9, provider calendar",
      "Counsel-role note": "Pierce/Morse.",
      "Category": "THERAPY AND MAKE-UP LOGISTICS"
    },
    {
      "No.": "23",
      "Unanswered / disputed question": "Was there any standing make-up rule or prompt-notice protocol?",
      "Why material": "Prospective enforcement can eliminate repeat disputes.",
      "Best source": "S11, emails",
      "Counsel-role note": "Morse/Pierce.",
      "Category": "THERAPY AND MAKE-UP LOGISTICS"
    },
    {
      "No.": "24",
      "Unanswered / disputed question": "Was individual counseling made available to the child; who was the provider; did the child attend; and what parent-access structure applied?",
      "Why material": "Relevant to child support, adult-conflict burden, and records access.",
      "Best source": "S8, provider records",
      "Counsel-role note": "Morse/provider custodian.",
      "Category": "THERAPY AND MAKE-UP LOGISTICS"
    },
    {
      "No.": "25",
      "Unanswered / disputed question": "What recommendations did Pierce make about progression, individual counseling, or adult coordination, and what happened afterward?",
      "Why material": "Connects clinical recommendations to implementation acts.",
      "Best source": "Pierce records/testimony",
      "Counsel-role note": "Pierce; do not rely on counsel summaries.",
      "Category": "THERAPY AND MAKE-UP LOGISTICS"
    },
    {
      "No.": "26",
      "Unanswered / disputed question": "Why were complete provider, dental, insurance, MaineCare, and authorization details not supplied in one usable response after the February 16 request?",
      "Why material": "Tests practical records access.",
      "Best source": "S2, S8; provider/insurer records",
      "Counsel-role note": "Morse/custodians.",
      "Category": "MEDICAL, SCHOOL, RECORDS, AND LEGAL MESSAGING"
    },
    {
      "No.": "27",
      "Unanswered / disputed question": "Who supplied the school mailing/contact data showing [private address omitted], and when was Plaintiff's direct information corrected?",
      "Why material": "Tests direct notice and data integrity.",
      "Best source": "S9; school audit/history",
      "Counsel-role note": "School custodian.",
      "Category": "MEDICAL, SCHOOL, RECORDS, AND LEGAL MESSAGING"
    },
    {
      "No.": "28",
      "Unanswered / disputed question": "What concrete plan addressed 18.5 absences, 68 tardies, and the reported 63 B1 tardies?",
      "Why material": "Links school punctuality to child impact and prospective relief.",
      "Best source": "S9; school records",
      "Counsel-role note": "Morse/school official.",
      "Category": "MEDICAL, SCHOOL, RECORDS, AND LEGAL MESSAGING"
    },
    {
      "No.": "29",
      "Unanswered / disputed question": "What were the current dental provider, recent and future appointment details, treatment plan, and direct records-access path?",
      "Why material": "A discrete records question carried in the July 1 list.",
      "Best source": "S8; dental records",
      "Counsel-role note": "Morse/provider.",
      "Category": "MEDICAL, SCHOOL, RECORDS, AND LEGAL MESSAGING"
    },
    {
      "No.": "30",
      "Unanswered / disputed question": "Why did the July 27 annual-physical notice omit time and location, and when were complete details supplied?",
      "Why material": "Tests completeness and promptness of notice.",
      "Best source": "S10; Gmail thread",
      "Counsel-role note": "Documents/Morse.",
      "Category": "MEDICAL, SCHOOL, RECORDS, AND LEGAL MESSAGING"
    },
    {
      "No.": "31",
      "Unanswered / disputed question": "What exact operative PFA or family-order language was relied on for the categorical statement that Plaintiff could not attend the medical office?",
      "Why material": "The legal restriction was asserted as settled and then carried into the child-facing event.",
      "Best source": "S10, operative orders",
      "Counsel-role note": "Legal issue; documents control.",
      "Category": "MEDICAL, SCHOOL, RECORDS, AND LEGAL MESSAGING"
    },
    {
      "No.": "32",
      "Unanswered / disputed question": "What was communicated to the child before the August 3 call, by whom, and in what words?",
      "Why material": "The child stated he was \"pretty sure\" Plaintiff was not supposed to be there; source remains unresolved.",
      "Best source": "S10-S11; native communications",
      "Counsel-role note": "Morse/Plaintiff; possibly device evidence; do not assume source.",
      "Category": "MEDICAL, SCHOOL, RECORDS, AND LEGAL MESSAGING"
    },
    {
      "No.": "33",
      "Unanswered / disputed question": "Did any adult communicate a purported restriction to the provider, and what did the provider record?",
      "Why material": "Tests whether the disputed legal position affected healthcare access.",
      "Best source": "Provider notes, phone logs, audit trail",
      "Counsel-role note": "Provider custodian.",
      "Category": "MEDICAL, SCHOOL, RECORDS, AND LEGAL MESSAGING"
    },
    {
      "No.": "34",
      "Unanswered / disputed question": "What changed in the portal/proxy/demographic record, when, and by what user or system process?",
      "Why material": "Determines cause of the observed access condition without speculation.",
      "Best source": "Portal audit logs; preservation request",
      "Counsel-role note": "Provider IT/records custodian.",
      "Category": "MEDICAL, SCHOOL, RECORDS, AND LEGAL MESSAGING"
    },
    {
      "No.": "35",
      "Unanswered / disputed question": "How did the child acquire adult-litigation terminology reflected in counseling or communications, and what safeguards were used to comply with the non-disparagement provisions?",
      "Why material": "Relevant to prospective adult-only messaging and child burden; causation must be proved, not assumed.",
      "Best source": "S7-S8; Pierce; native messages",
      "Counsel-role note": "Pierce/Morse; Bedard's May 1 denial is documentary evidence.",
      "Category": "MEDICAL, SCHOOL, RECORDS, AND LEGAL MESSAGING"
    },
    {
      "No.": "36",
      "Unanswered / disputed question": "What single adult-to-adult communication protocol will govern urgent, time-sensitive, and weekly nonurgent implementation questions?",
      "Why material": "A clear protocol can reduce both nonresponse and excessive correspondence.",
      "Best source": "S11 proposed order",
      "Counsel-role note": "Prospective judicial determination.",
      "Category": "MEDICAL, SCHOOL, RECORDS, AND LEGAL MESSAGING"
    }
  ],
  "counsel_role_screen": [
    {
      "Topic": "1. Stated counsel/client compliance review",
      "Bedard's own statement / conduct": "Apr. 21: after proof was provided, \"Amanda and I will review\" whether it met the Order. [S6]",
      "Other available sources": "Email itself; Morse; proof-transmittal records; court filings; treating professionals.",
      "Privilege / work-product concern": "Client advice and mental impressions may be privileged or protected. Questions must be limited to nonprivileged acts, communications to Plaintiff/third parties, and any factual assertion counsel intends to make at hearing.",
      "Rule 3.7 assessment": "POTENTIALLY MATERIAL, BUT NOT YET NECESSARILY UNIQUE. It becomes the strongest Rule 3.7 issue only if Bedard personally made the operative sufficiency determination and intends to prove it through facts unavailable elsewhere.",
      "Recommended treatment": "Require prehearing disclosure: Will counsel offer firsthand facts about the review, criteria, receipt of proof, or conclusion? If yes and material, conduct a necessity/privilege hearing and require advocate-witness election."
    },
    {
      "Topic": "2. \"We have no proof\" / evidence-receipt assertion",
      "Bedard's own statement / conduct": "Mar. 18: Bedard stated there was no proof of completed obligations. [S4]",
      "Other available sources": "Emails, attachments, certified mail, eFile/service receipts, providers, Morse.",
      "Privilege / work-product concern": "Whether counsel received documents is generally nonprivileged; why counsel interpreted them a certain way may implicate protected analysis.",
      "Rule 3.7 assessment": "USUALLY DOCUMENTARY. Bedard is not necessary if receipt/nonreceipt can be established by transmittal records and the contents of the proof.",
      "Recommended treatment": "Use authenticated service/transmittal evidence. Bar counsel from converting argument into personal testimony. Reserve testimony only if receipt is genuinely disputed and unobtainable elsewhere."
    },
    {
      "Topic": "3. Child-controls-contact legal position",
      "Bedard's own statement / conduct": "Mar. 18, Apr. 6, and Apr. 21 emails state that the child determines contact or cannot be forced, even if compliance is shown. [S4-S6]",
      "Other available sources": "Emails; order text; Morse; Pierce; calendars.",
      "Privilege / work-product concern": "Legal advice to client is privileged; the outward position communicated to Plaintiff is not hidden and is preserved in the emails.",
      "Rule 3.7 assessment": "NOT A NECESSARY-WITNESS ISSUE BY ITSELF. The writings prove the communicated position. The Court decides the order's legal effect.",
      "Recommended treatment": "Admit the complete emails for context. Ask the Court to prohibit counsel from adding unrecorded personal factual claims while arguing the interpretation."
    },
    {
      "Topic": "4. Response-filtering policy",
      "Bedard's own statement / conduct": "Apr. 21: Morse would not respond to each communication and would inform Plaintiff when she believed she needed to. [S6]",
      "Other available sources": "Email; Morse; request-and-response ledger.",
      "Privilege / work-product concern": "Internal advice may be privileged; the policy as communicated is documented.",
      "Rule 3.7 assessment": "DOCUMENTARY / MORSE TESTIMONY. No necessity showing merely because counsel authored the message.",
      "Recommended treatment": "Use the email and objective response ledger. Do not predicate disqualification on silence or authorship alone."
    },
    {
      "Topic": "5. July 29 medical-exclusion / PFA position",
      "Bedard's own statement / conduct": "Morse asserted categorical exclusion and copied Bedard after Plaintiff disputed the interpretation. [S10]",
      "Other available sources": "Morse; operative PFA and family orders; provider communications; August 3 records.",
      "Privilege / work-product concern": "No adverse inference should be drawn from counsel silence alone. Any client advice is privileged.",
      "Rule 3.7 assessment": "NOT NECESSARY ON CURRENT RECORD. The asserted restriction and operative orders are documentary; Morse made the statement.",
      "Recommended treatment": "Focus on exact order language and provider/child communications. Add Bedard only if evidence shows he personally conveyed the restriction to a third party or offers personal facts."
    },
    {
      "Topic": "6. May 1 denial of litigation exposure",
      "Bedard's own statement / conduct": "Bedard wrote that he had confirmed with Morse that the child had not seen or been told anything. [S7]",
      "Other available sources": "Email; Morse; Pierce; child-facing communications if lawfully available; device/account evidence.",
      "Privilege / work-product concern": "The underlying client communication is likely privileged; the outward denial is admissibility-dependent documentary evidence.",
      "Rule 3.7 assessment": "GENERALLY NOT NECESSARY. Counsel was relaying his client's position, not an eyewitness account.",
      "Recommended treatment": "Use the email as a party-position communication, subject to evidentiary ruling. Obtain facts from Morse, Pierce, or records."
    },
    {
      "Topic": "7. Proposed-order / staff-forwarding process",
      "Bedard's own statement / conduct": "May 13 forwarding shows a draft sent for e-signing and filing. [S13]",
      "Other available sources": "Filed version, metadata, staff custodian if genuinely disputed, docket record.",
      "Privilege / work-product concern": "Drafting process and strategy often implicate work product; ordinary staff preparation is not misconduct.",
      "Rule 3.7 assessment": "COLLATERAL TO THE OCTOBER 8 ENFORCEMENT ISSUES unless a specific factual representation in a proposed order is itself material to the surviving motion.",
      "Recommended treatment": "Do not lead with this. Use only after identifying exact disputed language, its source, and why the filed document cannot speak for itself."
    },
    {
      "Topic": "8. Any personal-knowledge assertion at the hearing",
      "Bedard's own statement / conduct": "Risk arises if counsel narrates what he personally received, reviewed, decided, told a provider, or learned outside admitted evidence while also examining witnesses and arguing.",
      "Other available sources": "Depends on the assertion; many facts should come from emails, records, Morse, Pierce, or custodians.",
      "Privilege / work-product concern": "Privilege must be resolved before testimony. Counsel cannot use privilege as both shield and source of factual advocacy.",
      "Rule 3.7 assessment": "STRONGEST BASIS FOR ADVANCE COURT CONTROL. Rule 3.4(e) bars personal-knowledge assertions in trial unless counsel testifies; Rule 3.7 then governs whether he can continue as advocate.",
      "Recommended treatment": "Order an advance election: remain advocate and confine facts to admitted evidence, or identify proposed testimony. If testimony is necessary and contested, require substitute hearing counsel or other tailored relief."
    }
  ],
  "sources": [
    {
      "id": "S1",
      "source": "Findings and Order dated February 11, 2026, YORDC-FM-10-190 / BIDDC-PA-24-1285, especially pp. 12-17: shared parental rights, records access, weekly therapy, electronic contact, in-person progression, prompt communication, and non-disparagement."
    },
    {
      "id": "S2",
      "source": "Justin Tahai email to Patrick S. Bedard, February 16, 2026, \"Implementation of February 11, 2026 Order - Compliance, Notice, and Documentation (Pending Appeal),\" requesting contact, therapy, transport, in-person, school, medical, insurance, and authorization logistics."
    },
    {
      "id": "S3",
      "source": "Patrick S. Bedard response, February 16, 2026, Gmail message 19c683b10d17f776."
    },
    {
      "id": "S4",
      "source": "Patrick S. Bedard response, March 18, 2026, Gmail message 19d02542a43d3e19."
    },
    {
      "id": "S5",
      "source": "Patrick S. Bedard response, April 6, 2026, Gmail message 19d63841a5bb511f."
    },
    {
      "id": "S6",
      "source": "Patrick S. Bedard response, April 21, 2026, Gmail message 19db1ee3dff26d1c."
    },
    {
      "id": "S7",
      "source": "Patrick S. Bedard response concerning litigation exposure, May 1, 2026, Gmail message 19de566833f85675."
    },
    {
      "id": "S8",
      "source": "Justin Tahai, \"Outstanding Response Items - the child / Implementation / Records Access,\" July 1, 2026, Gmail message 19f1f7b9a76cdf25; no reply appears in that thread."
    },
    {
      "id": "S9",
      "source": "June 18-22, 2026 school-record / attendance / parent-access materials summarized in Master Timeline v17B: report-card totals, period-attendance detail, mailing block, and principal-meeting record."
    },
    {
      "id": "S10",
      "source": "July 27-August 4, 2026 annual-physical and legal-restriction email threads, including Gmail messages 19fac205bc1d9123, 19fade3ff6e88cc2, 19fc808625df0145, 19fcebe5d1881416, and related messages."
    },
    {
      "id": "S11",
      "source": "August 7, 2026 FM-070 Motion to Enforce service packet: YORDC-FM-2010-00190_RULE_5_SERVICE_COPY_20260807.pdf."
    },
    {
      "id": "S12",
      "source": "August 14, 2026 Scheduling Notice and Procedural Order: hearing date, surviving filing, response limitation, deadlines, and motions-in-limine deadline."
    },
    {
      "id": "S13",
      "source": "Patrick S. Bedard forwarding email and attachment amandaobjectiontwo.docx, May 13, 2026, Gmail message 19e22b4fe2c3a864. Included only as a secondary counsel-role screening item; ordinary staff drafting is not itself misconduct."
    },
    {
      "id": "S14",
      "source": "Maine Rule of Professional Conduct 3.7; Maine Rule of Professional Conduct 3.4(e); Pacheco v. Libby, O'Brien, Kingsley & Champion, LLC, 2024 ME 39; Morin v. Maine Education Association, 2010 ME 36."
    }
  ]
}