Section 649-103-5 - INFORMAL DISCOVERY1. Defense counsel should request and review all discoverable material in the State agency's case file.A. Defense counsel should request and review the agency case file as early during the course of representation as possible. The file contains useful documents that defense counsel may not yet have and that may instruct defense counsel on the agency's case theory. (1) If the agency case file is inaccurate, defense counsel should seek to correct it.(2) Defense counsel must request and review the case file periodically because information is continually added by the agency.2. Defense counsel should obtain all necessary documents. A. As part of the discovery phase, defense counsel should gather all relevant documentation regarding the case that might shed light on the allegations, the service plan and the client's strengths as a parent. (1) Defense counsel should not limit the scope as information about past or present criminal, protection from abuse, private custody or administrative proceedings involving the client can have an impact on the abuse and neglect case.(2) Defense counsel should also review the following kinds of documents: social service records; court records; medical records; school records; and, evaluations of all types.(3) Defense counsel should be sure to obtain reports and records from service providers. Discovery is not limited to information regarding the client, but may include records of others such as the other parent, stepparent, child, relative and non-relative caregivers.94- 649 C.M.R. ch. 103, § 5