The plan says parents must demonstrate the ability to protect the children from abuse and neglect, and the ability to "provide a home free of persons who have or will abuse or neglect the children."
The service plan goals also say the parents must show that they understand what is meant by abuse. A CPS supervisor testified at a hearing last month that sect girls believed no age was too young to get married.
The plan asks parents to cooperate with DNA testing and to help authorities establish paternity and family relationships. Tasks include participating in parenting classes, psychiatric evaluations and following the recommendations of counselors.
McCown called the service plans typical for child custody cases. "The parent has to have a stable place to live and a stable job and a real willingness not to repeat past patterns," he said.
But lawyers for the parents complain that the state is using the same plan for all children, regardless of circumstances.
"Each and every client has received that exact same document," said Cynthia Martinez of Texas Rio Grande Legal Aid, which represents about 50 sect mothers.
Some mothers are in monogamous relationships and live in single-family households, unlike many members of the sect, who live in group family homes, she said.
Crimmons, the CPS spokesman, called the plans a starting point and said caseworkers would meet with individual clients before today and add details specific to each child. As of Friday afternoon, many had not met with their caseworkers, according to Martinez.