To Whom It May Concern:

Pursuant to the Massachusetts Public Records Law, I hereby request the following records:

All Massachusetts [MA] Trial Court Employees "Contracts" (and/or other synonyms such as, but not limited to, memorandums of understanding, other arrangements/agreements [including 45 CFR § 302.34 "cooperative arrangements"], Interdepartmental Service Agreements (ISAs), Vendor Applications, Vendor Agreements, etc.) and/or any other documentation enabling these Employees to voluntarily participating in the Title IV-D Program.

** Before you respond to tell me, I want to make it very CLEAR that we BOTH ALREADY KNOW that the MA Judicial Branch is NOT included in the definition of public records within the MA Public Records "Law", but TAKE NOTE that this DOES NOT APPLY when a MA Judical Branch Employee decides to act OUTSIDE of their MA Judicial Branch government role and instead decides to VOLUNTARILY participate in the Title IV-D Program by offering Title IV-D Services. **

If there is still confusion on your end, then I believe your Agency needs to review the U.S. court case Wehunt v. Ledbetter, 875 F. 2d 1558, 1563 (11th Circuit 1989) where it stated verbatim that:
"Although state participation in the Social Security Act itself is mandatory, participation by a state in the IV-D program is [100%] voluntary."

Take note of ALL of the following according to the above-mentioned Wehunt v. Ledbetter case:
1.a. Since participation in the Title IV-D program is 100% VOLUNTARY, then all Title IV-D program participants are acting outside of their MA Judical Branch Employee role and instead are then employed as "Title IV-D Contractors" providing those IV-D services.
1.b. This includes (but is not limited to) hosting "IV-D Administrative Hearings" at the nineteen (19) Massachusetts Probate & Family Courts.
1.c. This means that this documentation is available via a MA Public Records Request as these Employees are not acing within their MA Judicial Branch government role when they participate in the Title IV-D Progam.

2.a. These "Title IV-D Contractors" include ALL of the 19 court "Justices", such as Barnstable's First Justice Arthur C. Ryley.
2.a.a. For example, if Mr. Ryley was IN REALITY acting in his MA Judicial Branch government role, then he would be called a "Judge", as is expected within the judiciary.
2.b. These "Title IV-D Contractors" include ALL of the 19 court's Registers, such as Barnstable's Anastasia Welsh Perrino.
2.c. These "Title IV-D Contractors" include ANY and ALL MA Trial Court Employees VOLUNTARILY PARTICIPATING IN THE TITLE IV-D PROGRAM.

3. To reiterate, this request is seeking any and all documentation enabling MA Judical Branch Employees to act OUTSIDE of their MA Judicial Branch government roles and instead to VOLUNTARILY participate [Wehunt v. Ledbetter] in the Title IV-D Program by offering Title IV-D Services.

I also request that, if appropriate, fees be waived as we believe this request is in the public interest, as suggested but not stipulated by the recommendations of the Massachusetts Supervisor of Public Records. The requested documents will be made available to the general public free of charge as part of the public information service at MuckRock.com, processed by a representative of the news media/press and is made in the process of news gathering and not for commercial usage.

I expect the request to be filled in an accessible format, including for screen readers, which provide text-to-speech for persons unable to read print. Files that are not accessible to screen readers include, for example, .pdf image files as well as physical documents.

In the event that there are fees, I would be grateful if you would inform me of the total charges in advance of fulfilling my request. I would prefer the request filled electronically, by e-mail attachment if available or CD-ROM if not.

Thank you in advance for your anticipated cooperation in this matter. I look forward to receiving your response to this request within 10 business days, as the statute requires.

Sincerely,

Josh Coffin