Check out this link on the revised PLO and how it affects Social Workers and their statements:
http://www.judiciary.gov.uk/Resources/JCO/Documents/Reports/pfd-process-reform-revised-plo-may-2013.pdf
Separate out immediate risks and long terms risks in your statement and drill down to the why eg yea lack of supervision is a problem but why specifically, give examples.
In court when giving evidence add your analysis when giving evidence in chief, ie to your own counsel to avoid it coming up in cross examination
Be ready to give top 5 risk concerns proving kids at immediate risk of harm. Have them prepared
If you have time to find a research case to back up your evidence then do eg to prove why contact arrangements are the right amount
Ask your counsel to start by asking whether you have given evidence before, if its your first time as will make judge sympathetic with you
Meet counsel early before court to give them updates on case
Be clear on separating fact and opinion and first hand vs second hand account.
Recognise positives about parents to show you are being balanced.
Show you have considered the harm of removing child vs harm of keeping them in home.
Use legal terms like 'good enough parenting'. Don't say we want to improve child's outcomes, that's not the court/state's job, that's social engineering
If applying for ICO, you really have to show kids at immediate risk of harm now and can't wait til final hearing. Especially difficult in neglect cases.
