Page 18 - Juvenile Practice is not Child's Play

Concluding the Private Interview of the Client

When concluding the interview, instruct your client as to the following:

1. Say nothing at all to the police, tell them nothing under any circumstances, and reply to all police
questions or approaches by saying that the client’s lawyer has told the client not to answer questions or to talk

with anyone unless the lawyer is present.

2. Tell police officers who start any conversation with the client or who make any requests of the client that they

need to talk to counsel about whatever they want; show the officers counsel’s business card and tell them
to phone or email counsel; and (if counsel has given the client a rights card) show that to the officers as well.

Rights Card Statement:

My lawyer has instructed me not to talk to anyone about my case or anything else and not to answer
questions or reply to accusations. On advice of counsel and on the grounds of my rights under the Fifth

and Sixth Amendments, I shall talk to no one in the absence of counsel. I shall not give any consents or
make any waivers of my legal rights. Any requests for information or for consent to conduct searches
or seizures or investigations affecting my person, papers, property, or effects should be addressed to
my lawyer, whose name, address, and phone number are. I want all communications with the
authorities henceforth to be made only through my lawyer. I request that my lawyer be notified and

allowed to be present if any identification confrontations, tests, examinations, or investigations of any
sort are conducted in my case, and I do not consent to any such confrontations, tests, examinations, or
28
investigations.

3. Handle approaches by prosecuting attorneys in the same way, and under no circumstances discuss
any offer or deal with the police or prosecuting attorneys in counsel’s absence.

4. Discuss the case with no one, including cellmates, co-respondents, adults who are being charged in
criminal court with the same or connected crimes, lawyers for any such co-respondents or adult defendants,
other purported juvenile or adult co-perpetrators, reporters, or any persons who may have been involved in

events relating to the case or who may have information about those events; and tell anyone who wants to
discuss the case or who has information about it to contact counsel.

28 See id.; Representing Clients Before Initial Hearing; Steps To Take if a Client Is at the Police Station or Is “Wanted” by the Police, NJDC
Trial Manual for Def. Att’y in Juv. Delinq. Cases 3, 43 (2019), https://njdc.info/wp-content/uploads/2019/Chap-3-Before-the-Initial-
Hearing-2019-edition.pdf