training session will focus on defending termination of parental rights cases based on a cause of action for permanent neglect under 384-b(4)(d). After briefly reviewing the statutory scheme for termination cases, the session will look at what agencies must prove to demonstrate permanent neglect and address development of a defense strategy. We will examine the common defenses to permanent neglect causes of action and how to prove them at trial, emphasizing discovery tools, objections, trial preparation skills and common evidentiary issues. We will also cover topics related to preparation of party and non-party witnesses, including experts.